John G. Goettee, Jr. and Marian Goettee - Page 23




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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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