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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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