Victoria Rae Moore - Page 13

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          States, 466 F.2d 131, 136 (10th Cir. 1972); Cory v. Commissioner,           
          159 F.2d 391, 392 (3d Cir. 1947), affg. a Memorandum Opinion of             
          this Court.  In this case, petitioner represented herself when              
          she agreed to settle without formally raising the question of               
          section 6015 relief.                                                        
               As was stated in Huynh v. Commissioner, T.C. Memo. 2006-180:           
                    Court cases have not yet clearly defined                          
               "meaningful participation" in all respects, although we                
               have indicated that "merely [complying]" with a                        
               spouse's instructions to sign various pleadings and                    
               other documents filed in prior litigation is not                       
               conclusive of meaningful participation, Thurner v.                     
               Commissioner, supra at 53, but signing court documents                 
               and participating in settlement negotiations are                       
               indicators of meaningful participation.  Id.; Monsour                  
               v. Commissioner, supra.                                                
                    In Trent v. Commissioner, T.C. Memo. 2002-285, we                 
               suggested that a taxpayer who participated in meetings                 
               with an Appeals officer and who voluntarily signed a                   
               decision document generally would be regarded as having                
               participated meaningfully, regardless of whether the                   
               taxpayer was represented by counsel.  [Fn. ref.                        
               Here, petitioner was represented by counsel for an extended            
          period of time.  Significantly, however, after the representation           
          ended, petitioner was advised by respondent of the existence of             
          section 6015 and the need to amend her pleading if she wished to            
          seek relief under that Code provision.  That advice was provided            
          prior to the time that petitioner voluntarily agreed to settle              
          the outstanding issues in the two cases, which did not include              
          the question of relief under section 6015.  The fact that Mr.               
          Moore urged that she agree to resolve the controversy does not              

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