- 17 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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