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innocent spouse and didn’t find out until years later it was a
scam.”
On September 8, 2003, respondent’s counsel mailed petitioner
a letter, with respect to both docketed cases, advising that if
she believed she was entitled to section 6015 relief, she should
amend her pleadings. In addition, respondent’s counsel sent
petitioner a copy of the text of section 6015 along with that
letter. On September 18, 2003, respondent’s counsel spoke with
petitioner by telephone to arrange a meeting, and in that
conversation, petitioner acknowledged that she had read section
6015 provided with the September 8, 2003, letter. A pretrial
meeting was held on September 30, 2003, and at that meeting
petitioner informed respondent’s counsel that she would notify
respondent if she intended to concede the two Tax Court cases.
On October 9, 2003, petitioner engaged in a telephone
conversation with Mr. Moore, respondent’s counsel, and the Court.
During that conversation, respondent’s counsel advised the Court
that she believed that the assessments of the tax for the taxable
years 1987 through 1991 might have been barred by the running of
the period for assessment. Thereafter, both of petitioner’s
cases were set for trial on July 26, 2004, at Portland, Oregon.
On April 29, 2004, respondent’s counsel spoke with petitioner,
who advised that she intended to settle the pending cases. On
May 18, 2004, respondent conceded, by means of an amended answer,
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