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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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