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petitioner's case was transferred from respondent's District
Counsel office in Houston to respondent's District Counsel office
in Oklahoma City for trial preparation because petitioner had
designated Oklahoma City as the place of trial. Thereafter, the
record demonstrates that respondent acted reasonably promptly in
settling the case. Thus, shortly after being assigned the
defense of this case, respondent's counsel contacted petitioner's
counsel. Thereafter, respondent's counsel acted promptly to
retrieve the filed return from the Austin Service Center. Upon
receiving the filed return, respondent's counsel again acted
promptly in ordering transcripts of account in order to verify
the correctness of the return. After those transcripts were
received in January 1996, respondent's counsel immediately
conceded that petitioner had paid her tax liability for 1988 and
apparently also conceded that petitioner was not liable for the
addition to tax under section 6654(a). Respondent's counsel
conceded the balance of the case on March 1, 1996, and no later
than March 5, 1996, he mailed the form of decision to
petitioner's counsel for his signature. Thus, this case was
completely settled 6 months after respondent filed the answer.
In this regard, we observe that some delay in the settlement
process, in and of itself, does not make respondent's position
unreasonable. See Sokol v. Commissioner, 92 T.C. at 765, and
cases cited therein.
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