John G. Goettee, Jr. and Marian Goettee - Page 16

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          C.  The Settlement Process - Generally                                      
               Although Rowland’s caseload was about half of her normal               
          caseload in the spring of 1993, her caseload had returned to                
          normal, about 100-120 cases, about the same time the Barrister              
          cases were assigned to her.  Because of the increase in her                 
          workload, Rowland did not send any settlement letters to any                
          Barrister taxpayers until about September of 1993.                          
               Rowland sent settlement letters in groups of 10 to 15.  The            
          settlement letters (1) stated the terms of the settlement offer,            
          (2) asked the recipients to submit to Rowland copies of their               
          canceled checks (hereinafter sometimes referred to as                       
          verification information) within 10 days so that she could verify           
          the recipients’ actual cash investment in the partnership, and              
          (3) stated that upon receipt of the verification information,               
          Rowland would send to the Barrister taxpayer computations which             
          showed the tax effects of the settlement offer to that taxpayer.            
               The settlement letters generated a significant and generally           
          prompt response from many of the Barrister taxpayers.  More than            
          half of the Barrister taxpayers who responded to the settlement             
          offer submitted their verification information within the                   
          requested 10 days.  Rowland also received numerous phone calls              
          regarding the settlement offer, many of which concerned the                 
          amount of interest that would be assessed.                                  

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