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beginning on March 17, 1997, in Chicago, Illinois.
In October 1996, at or about the time that the trial notice
was sent to petitioner, Jaffe and Coleman met with respondent’s
District Counsel attorney in Chicago to discuss the issues raised
by the notice of deficiency.
On March 12, 1997, shortly before the scheduled trial
session, John signed and dated a stipulated decision. The
stipulated decision reflected a complete concession of the
deficiencies and penalties determined by respondent in the notice
of deficiency. The Court entered the stipulated decision on
March 26, 1997, and so notified petitioner by mailing a conformed
copy on that date to petitioner at its Highland Park office.
F. Post-Decision Developments
In July 1998, CJ&J terminated Jaffe’s status as a partner in
the firm.
In August 1998, CJ&J6 commenced a civil action against Jaffe
in the Circuit Court for Cook County, Illinois. The complaint
included counts for fraud, embezzlement, and forgery. This
action was apparently still pending at the time of the
evidentiary hearing in the present case.
In or about July or August 1998, petitioner retained an
attorney for the purpose of addressing its tax liabilities for
fiscal years for which Jaffe, as well as Coleman and CJ&J, had
6 Actually, the successor firm to CJ&J.
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