John G. Goettee, Jr. and Marian Goettee - Page 14

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          Barrister taxpayers whose surnames began with letters other than            
          A.  In these circumstances, Winkler and Craig processed all of              
          the cases with common representation at the same time.  Another             
          category of deviations from strict alphabetical sequence involved           
          taxpayers or their representatives who telephoned Winkler or                
          Craig, described their circumstances, and indicated their                   
          agreement with the proposed settlement.  Petitioners’ case did              
          not fall into either of the foregoing categories of cases in                
          which respondent deviated from strict alphabetical sequence.                
               In the spring of 1993, the Commissioner’s Appeals Office in            
          Cincinnati, Ohio (hereinafter sometimes referred to as the                  
          Cincinnati office), learned of the Barrister case settlements               
          that Winkler and Craig were processing.  At that time, Appeals              
          officers in the Cincinnati office had caseloads of about 50-60              
          cases, which was about half of their normal caseloads.  The chief           
          of the Cincinnati office, the associate chief (Paul R. Becker,              
          hereinafter sometimes referred to as Becker), and Appeals Officer           
          Fran Rowland (hereinafter sometimes referred to as Rowland) went            
          to the Louisville office to discuss with Winkler and Craig the              
          possibility of the Cincinnati office processing some of the                 
          Barrister case settlements.  By the end of the meeting, it was              
          decided that the Cincinnati office would take some 200 of the               
          pre-TEFRA Barrister cases.  Winkler remained responsible for                
          executing Tax Court decision documents on behalf of the                     

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