- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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