Laurence L. and Patricia Jacobs - Page 17




                                       - 17 -                                         
          September 1987 Through November 17, 1991                                    
               The evidentiary record for the period September 1987 through           
          November 17, 1991, is scant.  Sometime after Agent McBrien's last           
          meeting with TLP representatives during August 1987, but before             
          April 1989, Agent McBrien forwarded the TLP case to respondent's            
          Quality Review branch.  The exact date, or even the approximate             
          date, that he forwarded the case to Quality Review is unknown.              
          Because Agent McBrien concluded his last meeting with TLP's tax             
          matters partner and its attorney during August 1987, it is                  
          reasonable to infer that the TLP case was not forwarded to                  
          Quality Review any earlier than September 1, 1987.    When Agent            
          Lester was asked at trial about the handling of the TLP case                
          while it was in Quality Review, Agent Lester was not able to                
          recall the case at all.  The first evidence in the record                   
          indicating that the TLP case was being considered by Quality                
          Review was when Quality Review returned the case, during April              
          1989, to Agent McBrien's examination group because of                       
          deficiencies in the case file and because Quality Review wanted             
          him to reexamine his recommendation not to determine penalties.             
          Agent McBrien's examination group eventually resubmitted the TLP            
          case to Quality Review during September 1989.  Nothing further              
          about that period is contained in the record.                               










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