- 149 - Mr. DeCastro that Mr. Sims had no authority to enter into such a settlement.64 Mr. Sanchez promptly notified David Jordan (Mr. Jordan), Acting Chief Counsel (National Office) of the basic facts surrounding the Thompson settlement. Mr. Jordan told Mr. Sanchez that Chief Counsel attorneys in the Tax Litigation Division in the National Office would be brought into the matter for two reasons: The gravity of the situation and the role of the Tax Litigation Division in the National Office as the prime liaison of the Internal Revenue Service with the Tax Court. Mr. Jordan and Mr. Sanchez agreed that the Tax Court had to be notified immediately. Mr. Sanchez assigned Mr. Bakutes to investigate the matter on behalf of Regional Counsel. Mr. Bakutes spent several weeks gathering facts, so that the matter could be reported to the Tax Court. Mr. Bakutes recognized that he needed to move quickly because the period for appealing the decisions entered in the Thompson cases would expire on June 11, 1992. 64 Mr. Sanchez believed that Mr. Sims was acting outside the scope of his employment and authority when he deviated from the terms of the official project settlement offer in the Thompson cases, and when he purportedly used as a basis for settlement a transaction (Bauspar) that had occurred in a tax year over which he, as District Counsel, had no jurisdiction. We observe that the Thompsons' participation in the Bauspar program apparently originated in 1981--one of the years that the Thompsons had pending before the Court--although the record does not detail the deductions, if any, claimed by the Thompsons with respect to the Bauspar program on their 1981 return.Page: Previous 139 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154 155 156 157 158 Next
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