Victoria Rae Moore - Page 11

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               effective date of section 6015, relief under section                   
               6015 was not available in that proceeding.  * * *                      
               In this case, petitioner and Mr. Moore were embroiled in a             
          protracted controversy with respondent involving their “tax                 
          shelter” partnership losses.  The controversy covered the tax               
          decade including the years 1987 through 1997.  Respondent’s                 
          counsel, in October 2003, advised the Court that the period for             
          assessment had expired for the 1987 through 1991 tax years, and,            
          ultimately, respondent conceded the disputed deficiencies                   
          attributable to those years.  Petitioner and her husband filed              
          their petition pro se in the first of their deficiency suits and            
          then, after approximately 2 years, became represented therein by            
               Petitioner and her husband remained represented through the            
          filing of the petition in their second deficiency suit until                
          August 2003 when their attorneys were permitted to withdraw as              
          counsel of record.  It was after the withdrawal of their                    
          attorneys that settlement with the Government was discussed with            
          petitioner and Mr. Moore and the cases were resolved by agreement           
          of the parties.  Prior to executing the settlement, petitioner,             
          who was divorced from Mr. Moore, was sent letters from                      
          respondent’s counsel alerting her to the need to amend her                  
          pleadings if she wished to allege that she was entitled to relief           
          from the joint and several liability under section 6015.  In                
          addition, petitioner was sent a copy of the text of section 6015.           

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