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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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