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some respect. Once the Cincinnati office became more proficient
at drafting the proposed decision documents, proposed decision
documents were sent to Barrister taxpayers without first
obtaining the approval of either Winkler or Craig.
Normally, an Appeals officer in the Cincinnati office
working on a Barrister case required about 26 calendar days to
(1) verify the amount of the taxpayer’s cash investment, (2)
determine whether the taxpayer was involved in another tax
shelter, (3) input the taxpayer’s information into the computer,
(4) prepare the settlement documents, and (5) mail the settlement
documents to the taxpayer.
If a taxpayer accepted the settlement offer and returned the
signed decision document, then Rowland prepared and submitted to
Becker an appeals transmittal and case memorandum for his
approval. If Becker approved, then he signed the appeals
transmittal and case memorandum and transmitted the settlement
documents to Winkler. Winkler then reviewed the format and
contents of the decision documents, signed them, and forwarded
them to the Court for entry of decision. It ordinarily took
Winkler less than 1 hour to review and sign an average decision
document that did not have any problems. However, Winkler gave
priority to working on cases calendared for trial by the Court.
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