Victoria Rae Moore - Page 5

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          innocent spouse and didn’t find out until years later it was a              
               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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