John G. Goettee, Jr. and Marian Goettee - Page 15

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          Commissioner in Barrister cases.  The Louisville office retained            
          some of the pre-TEFRA Barrister cases which involved multiple tax           
          shelters.  The Cincinnati office picked up the cases from the               
          Louisville office in June of 1993.                                          
               The number of cases transferred to the Cincinnati office,              
          coupled with their complexity, created the need for Craig to                
          conduct an all-day training session about how to process the                
          settlement of these cases.  Employees in the Cincinnati office              
          who were to process the Barrister cases traveled to the                     
          Louisville office to attend this session.  The need for a                   
          training session to become able to settle a case was not typical.           
               About July of 1993, the Barrister cases were assigned to               
          Rowland and two other Appeals officers.  About 75 cases were                
          assigned to Rowland, about 75 to another Appeals officer, and               
          about 50 to the remaining Appeals officer.  Petitioners’ case was           
          among those assigned to Rowland.                                            
               Appeals officers in the Cincinnati office managed multiple             
          priorities while they processed the settlement of the Barrister             
          cases.  Cases nearing the end of the limitations period, and Tax            
          Court cases calendared for trial in Cincinnati and Columbus,                
          Ohio, were given a higher priority than the Barrister cases.                
          Rowland typically did all of the service center claim cases--               
          these, too, were given a higher priority than the Barrister                 

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