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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.
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Last modified: May 25, 2011