- 17 - 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 deficiencyPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: May 25, 2011