- 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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