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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
attorneys.
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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