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computations for each affected year, including in most cases
carryback years. The settlement documents showed not only the
deficiency amounts, but also the balances due. However, the
settlement documents did not show the amount of interest due.
Rowland then sent the settlement documents to the taxpayer. The
taxpayer was instructed that, if the taxpayer approved, then the
taxpayer was instructed to sign the proposed decision document
and return it to Rowland within 30 days.
Many people called to find out the amount of interest they
would have to pay. Rowland and the other Appeals officers
typically told those people that a “ballpark figure” would be
three or four times the deficiency due. If the people wanted
more precise information, then Rowland and the other Appeals
officers had a support office prepare computations, which then
were forwarded to those who inquired. Generally, the people who
inquired about interest did not return the decision document
until they received the requested information.
For about the first 6 months that the Cincinnati office
processed Barrister cases, Rowland and the other Appeals officers
sent the proposed decision documents to Winkler and Craig for
their approval before sending them to the Barrister taxpayers.
The Cincinnati and Louisville offices were in frequent contact
about drafts of the proposed decision documents during this time
because many of the proposed decision documents were incorrect in
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