John G. Goettee, Jr. and Marian Goettee - Page 13

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               The task of processing the settlement of the Barrister cases           
          fell to Winkler and an Appeals officer in respondent’s                      
          Louisville, Kentucky, office, hereinafter sometimes referred to             
          as the Louisville office.  Elmer Craig (hereinafter sometimes               
          referred to as Craig) succeeded Charles Bower as the Appeals                
          officer who shared with Winkler the responsibility of processing            
          the Barrister cases.                                                        
               The settlement offer was communicated to investors in                  
          Barrister partnerships by letter (hereinafter sometimes referred            
          to as settlement letters).  The settlement offer was intended to            
          be made available to every investor in a Barrister partnership.             
          However, Winkler decided to send only a few settlement letters at           
          any given time because he thought that he and Craig (the only               
          ones working on the settlements at this point) would not have               
          been able to process the settlement offer in a timely manner if             
          it was made simultaneously available to every investor in a                 
          Barrister partnership.  Also, the death and relocation of some of           
          the Barrister taxpayers or their representatives made it                    
          difficult for Winkler to communicate the settlement offer to some           
          of the Barrister taxpayers.                                                 
               Winkler and Craig generally processed the Barrister cases in           
          taxpayer alphabetical sequence.  They deviated from this system             
          if, for example, the person who represented a Barrister taxpayer            
          whose surname began with the letter A also represented other                

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Last modified: May 25, 2011