- 26 - authorizes Regional Counsels in nondocketed cases to enter into agreements with taxpayers. Paragraph 5 of the Delegation Order authorizes Regional Counsels in docketed cases under their jurisdiction "to enter into and approve written agreements with any person relating to the Internal Revenue tax liability of such person * * * in respect to related specific items affecting other taxable periods." (Emphasis added.) It is clear from both the documentary evidence and the testimony of Messrs. Kletnick and Berman that the settlement agreement and terms thereof were authorized by respondent's National Office. The decision to make a blanket settlement offer was made by James J. Keightley, respondent's Associate Chief Counsel (Litigation), who instructed that it be made. His instruction was "flown through" Agatha Vorsanger, respondent's North Atlantic Regional Counsel, and Mr. Kletnick confirmed the settlement to this Court in the name and on behalf of Ms. Vorsanger.6 Pursuant to Delegation Order No. 97, both Ms. 6 The following colloquy took place between the Court and Mr. Berman during the trial of the case herein: THE COURT: And how did that breakthrough come about? Did the national office, specifically Mr. Keightley, in any way influence the breakthrough? THE WITNESS (Berman): My recollection, your (continued...)Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
Last modified: May 25, 2011