- 6 -
decision document is “filed”, the IRS would send the partner a
“bill” for any additional tax due. The letter mentioned several
additional steps to be taken before individual computations could
be completed.
In July 1994, the Manhattan Appeals Office (Manhattan
Appeals) prepared computations for the settlement. A proposed
decision document based on the computations had to be prepared by
IRS District Counsel attorney Moira Sullivan (Sullivan).
Proposed computations and a proposed decision document were sent
to Lerner on September 9, 1995, and Lerner returned the signed
decision document to District Counsel on November 7, 1996. On
September 11, 1995, the IRS sent to Brown his first set of
closing agreements to be sent to the individual partners in
Manhattan Associates. Brown had the opportunity to send the
computations to the limited partners for their approval of the
settlement as reflected in the computations. The closing
agreements included a request that Brown’s wife also sign the
documents. On June 27, 1996, Brown returned the closing
agreements, but his wife did not sign them. On November 26,
1996, a second package of closing agreements was sent to Brown,
with a request that both he and his wife sign the documents.
After Brown received the second package of closing agreements, he
informed District Counsel that he was not married to his wife in
1982 and 1983. On January 3, 1997, revised closing agreements
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011