Trans World Travel - Page 10




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          beginning on March 17, 1997, in Chicago, Illinois.                          
               In October 1996, at or about the time that the trial notice            
          was sent to petitioner, Jaffe and Coleman met with respondent’s             
          District Counsel attorney in Chicago to discuss the issues raised           
          by the notice of deficiency.                                                
               On March 12, 1997, shortly before the scheduled trial                  
          session, John signed and dated a stipulated decision.  The                  
          stipulated decision reflected a complete concession of the                  
          deficiencies and penalties determined by respondent in the notice           
          of deficiency.  The Court entered the stipulated decision on                
          March 26, 1997, and so notified petitioner by mailing a conformed           
          copy on that date to petitioner at its Highland Park office.                
          F. Post-Decision Developments                                               
               In July 1998, CJ&J terminated Jaffe’s status as a partner in           
          the firm.                                                                   
               In August 1998, CJ&J6 commenced a civil action against Jaffe           
          in the Circuit Court for Cook County, Illinois.  The complaint              
          included counts for fraud, embezzlement, and forgery.  This                 
          action was apparently still pending at the time of the                      
          evidentiary hearing in the present case.                                    
               In or about July or August 1998, petitioner retained an                
          attorney for the purpose of addressing its tax liabilities for              
          fiscal years for which Jaffe, as well as Coleman and CJ&J, had              


          6 Actually, the successor firm to CJ&J.                                     





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