John G. Goettee, Jr. and Marian Goettee - Page 17

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               The Cincinnati office usually processed the Barrister case             
          responses on a first in, first out basis.  Consistent with this             
          policy, Barrister taxpayers who responded after the 10-day period           
          were still permitted to avail themselves of the settlement offer,           
          but their cases were processed after the cases for which                    
          verification information had already been provided.                         
               After receiving the verification information in a case,                
          Rowland’s first step was to compare that information to the                 
          amounts claimed on that taxpayer’s tax return.  The second step             
          was to determine whether that taxpayer was involved in any other            
          tax shelter activities for the relevant pre-TEFRA years and, if             
          so, then whether adjustments had been made regarding those other            
          tax shelter activities.  Many Barrister taxpayers were also                 
          involved in other tax shelters.  If the taxpayer was involved in            
          other tax shelters, then Rowland usually had to make phone calls            
          to other Internal Revenue Service Centers to find out the status            
          of the Commissioner’s actions regarding those other tax shelters.           
               The third step in the settlement process required Rowland to           
          input the taxpayer’s information into a computer which would                
          enable her to (1) generate a Form 5278 (Statement of Income Tax             
          Changes), (2) complete the requisite number of Form(s) 3623                 
          (Statements of Account), and (3) draft the proposed decision                
          document, hereinafter collectively referred to as the settlement            
          documents.  Rowland had to personally prepare the tax deficiency            

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Last modified: May 25, 2011