Victoria Rae Moore - Page 4

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               On July 30, 2002, Jennifer A. Gellner filed an entry of                
          appearance on behalf of the Moores in docket No. 27274-96, and on           
          that same date she filed a status report with the Court.  On                
          January 27, 2003, Attorneys Pearson, Merriam, and Gellner, filed            
          a petition regarding the Moores’ 1997 tax year in response to the           
          October 30, 2002, notice issued by respondent.  That case was               
          assigned docket No. 1460-03.  In that petition it was alleged               
          that the Moores were entitled to a theft loss for 1997, but no              
          section 6015 relief from joint and several liability was alleged.           
               On August 7, 2003, respondent’s counsel in docket No. 1460-            
          03 sent a letter to the Moores’ attorneys listing the issues in             
          that case and asking whether the list was accurate and complete.            
          Relief from joint and several tax liability was not listed as an            
          issue in the case.  It was also requested that the letter be                
          forwarded to petitioner and her husband if their attorneys                  
          withdrew from the case.  On August 14, 2003, Attorneys Pearson,             
          Merriam and Gellner moved to withdraw as counsel of record, and             
          their motions were granted August 18, 2003.                                 
               Thereafter, respondent sent petitioner two letters (August             
          25 and September 5, 2003) requesting that respondent be notified            
          of petitioner’s position in the case.  In a letter dated                    
          September 4, 2003, petitioner stated:  “I feel I should get the             
          same settlement that the other Hoyt partners get” and “I was an             

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