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Becker then delivered petitioners’ proposed decision document to
the records office of the Cincinnati office, which had 5 days to
send the proposed decision document to Winkler.
During 1993 and 1994, Winkler processed the settlement of
about 800 to 900 TEFRA Barrister cases. In addition to working
on the Barrister and Bromwell cases, Winkler also worked on some
general litigation cases, provided large case audit assistance,
assisted in the audit of “large taxpayers”, and worked on an
occasionally active large estate tax case.
Winkler signed petitioners’ decision document on April 25,
1995, and then forwarded it to the Court for entry of decision.
On May 2, 1995, the Court entered decision in petitioners’ case.
The relevant parts of the decision are set forth in table 2.
Table 2
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6653(a)(1) 6653(a)(2) 6659
1978 $14,606.59 -- -- $2,921.32
1979 8,207.59 -- -- 1,641.52
1981 1,144.00 -- -- 227.00
1982 4,298.00 -- -- --
The decision further provides that the entire deficiencies
for 1978, 1979, 1981, and 1982 were subject to the section
6621(c) rate.
The Court served a copy of the decision on respondent’s
National Office, which received it on May 2, 1995. The copy was
received in the Louisville office on May 8, 1995. On June 1,
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