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In 1993, Jaffe complained to James about the revenue agent.
In or about 1994 or 1995, Jaffe told James that the examination
had been resolved and that petitioner would be liable for
additional taxes; Jaffe also told James that any amounts paid by
petitioner would be refunded by the IRS or reimbursed by CJ&J.
James apparently accepted these statements at face value and did
not question Jaffe about them.
John was also aware of the examination of petitioner’s
income tax returns. John would periodically ask Jaffe, typically
at a social occasion such as during a round of golf, how the
examination was going. Jaffe would assure him that there was
nothing to worry about, and John would not inquire further.
In October 1994, CJ&J filed a protest on petitioner’s behalf
with the Internal Revenue Service. The protest served to
administratively appeal the determination of the revenue agent as
set forth in his report. The taxable years covered by the
protest were the fiscal years ended August 31, 1990 through 1993.
The protest was signed first by Coleman and then by James under
penalties of perjury.
In or about 1995, Jaffe and Coleman met with an IRS Appeals
Officer in Milwaukee to discuss petitioner’s protest of the
revenue agent’s report.
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