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September 1987 Through November 17, 1991
Sometime after his last meeting with TLP's representatives,
during August 1987, but before April 1989, Agent McBrien
forwarded the TLP file to respondent's Quality Review branch to
be reviewed for compliance with internal procedures. The exact
date, or even the approximate date, that Quality Review received
the TLP file is unknown.
Because TLP is governed by the Tax Equity and Fiscal
Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, 96 Stat. 324,
Quality Review had to perform special compliance checks. Michael
Lester was assigned to the Quality Review branch during 1989. As
a TEFRA coordinator, Agent Lester was responsible for reviewing
TEFRA cases to make sure that the administrative steps had been
followed properly. He was also responsible for preparing the
appropriate 60-day or 150-day letter. Agent Lester did not
remember the TLP case, nor did he recall when his unit received
the case. Agent Lester remembered keeping current with his
caseload and did not recall a backlog of cases in Quality Review
when he was there.
During April 1989, Quality Review returned the TLP case to
Agent McBrien's examination group because the case file did not
have any of the Schedules K-1 needed for processing. Quality
Review also asked Agent McBrien to look into other substantive
issues and to reexamine whether it was appropriate to impose
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