Estate of Lucille Abbott Sexton, Deceased, Ann Sexton Peterson, Executor - Page 7




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          5, 2000, and, ultimately, reflected in agreed or stipulated                 
          decision documents signed by the parties’ attorneys and filed               
          with the Court on January 23, 2001.                                         
               Mr. Harkavy was employed by respondent on September 29,                
          1998, to help determine the rights of a partnership in connection           
          with agreements executed with the Community Redevelopment                   
          Agency’s construction of a 73-story office building in downtown             
          Los Angeles.  Lorene Sams is a contracting officer employed by              
          respondent, in part, to facilitate the contracting for and                  
          procurement of expert witnesses.  Ms. Sams was requested by her             
          manager in the Appeals Office to hire an expert in a case                   
          commonly known as the “McGuire Partners” case.  Ms. Sams prepared           
          a statement of work and contacted the Los Angeles County Bar                
          Association referral service to obtain a list of attorneys with             
          expertise in the legal question in the McGuire Partners case.               
          She received a list of 6 to 10 attorneys from the bar                       
          association, which included Mr. Harkavy’s name.  The request for            
          bids issued by respondent included the following statement of               
          work:                                                                       
               1.  The Contractor shall travel to the Taxpayer                        
               Representative’s office in Los Angeles, CA.  While                     
               there, the Contractor shall peruse documents relating                  
               to the series of transactions described and shall                      
               determine which documents the Contractor requires to                   
               review.  The Contractor shall notify the IRS, in                       
               writing, outlining the specific documents which the                    
               Contractor’s [sic] requires copies of.  The IRS will                   
               request copies of these documents and provide copies to                
               the Contractor within 5 weeks after date of notification.              





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