- 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.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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