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Before becoming involved in the Plastics Recycling cases, Miller
represented investors in coal mining partnerships that had been
syndicated by Winer. Other attorneys, including Ronald
Fieldstone (Fieldstone), represented Winer at various times
during the section 7408 injunction proceeding.
The United States was represented at various times during
the section 7408 injunction proceeding by DOJ Tax Division Trial
Attorney Alice J. Davis (Davis) and many other attorneys on the
staff at the DOJ.
Davis graduated from law school in 1979. She then worked
for the IRS for 4-1/2 years before accepting a position with the
Tax Division of the DOJ in Washington, D.C. During her
employment with the IRS, Davis worked temporarily at the DOJ in
the Special Litigation Section. The function of the Special
Litigation Section was to bring injunction and penalty suits
under sections 6700 and 7408 against persons who were believed to
have promoted abusive tax shelters.3
During the evidentiary hearing, Davis could not recall how
the Winer injunction case was assigned to her. Davis recalled
that the Winer case was only one of many large cases assigned to
3 The Special Litigation Section of the Department of Justice
(DOJ), Tax Division, was created as a result of changes made to
the Internal Revenue Code by the Tax Equity and Fiscal
Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a),
96 Stat. 648. TEFRA secs. 320(a) and 321(a), 96 Stat. 611, 612,
added secs. 6700 and 7408, respectively.
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