- 4 - 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 anPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 NextLast modified: November 10, 2007