John G. Goettee, Jr. and Marian Goettee - Page 21

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               On December 2, 1993, John’s father, who was petitioners’               
          then representative,6 sent petitioners’ verification information            
          to Rowland.  At some point, Rowland examined petitioners’                   
          verification information and concluded that the amounts therein             
          matched the amounts claimed on petitioners’ relevant tax returns.           
               At some time between October 1 and October 15, 1994, Rowland           
          determined whether petitioners were involved in a tax shelter               
          other than TEA, and concluded that she did not need any further             
          information from petitioners to compute their tax liability.                
               At some time between October 15 and October 21, 1994,                  
          Rowland entered petitioners’ information into her computer.                 
          Rowland printed petitioners’ Form 5278 on October 21, 1994.  On             
          October 26, 1994, Rowland mailed the settlement documents                   
          (together with a Form 3610 (Audit Statement)) to petitioners.               
          Petitioners signed the decision document on November 25, 1994,              
          and mailed it to Rowland on December 14, 1994.  Petitioners                 
          enclosed the following letter to Rowland with their signed                  
          decision document:                                                          

               6  The parties have stipulated that John’s father was                  
          petitioners’ “representative” at the time of this letter.  The              
          parties also have stipulated that petitioners “proceeded pro se”            
          in this Court after Shematz’s death, in 1989.  We gather from               
          this that John’s father represented petitioners before the                  
          Internal Revenue Service, but not before this Court.                        

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