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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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Last modified: November 10, 2007