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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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