- 8 - On January 8, 1999, these consolidated cases were set for trial on June 14, 1999, in San Francisco, California. On a number of occasions from January through April of 1999, two of respondent’s Appeals officers contacted petitioners and/or petitioners’ counsel, requested a meeting, and requested that copies of certain documents relating to the separation agreement (and that during respondent’s audit had not been provided to respondent’s representatives) be provided to respondent’s Appeals Office representatives for review and consideration in connection with possible settlement discussions. Neither Haas nor petitioners’ counsel met with respondent’s Appeals Office representatives, and respondent’s Appeals Office representatives did not receive copies of the requested documents from petitioners or from petitioners’ counsel. By letter of May 3, 1999, petitioners’ counsel prepared and forwarded to respondent’s trial counsel a stipulation of facts for trial. At that point, respondent’s Appeals Office returned the administrative files relating to these cases to respondent’s District Counsel for trial preparation. On May 5, 1999, 6 weeks before the scheduled trial date, petitioners’ counsel sent to respondent’s trial counsel a written qualified offer to settle the underlying tax issues involved in these cases.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011