- 23 - 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,Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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