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Swanton programs. In September 1991, respondent and counsel
representing the TEFRA Swanton programs reached a basis of
settlement, but finalization of the settlement was deferred
pending the trial of the pre-TEFRA cases.
Two trials for the pre-TEFRA Swanton programs were conducted
in the Tax Court, one in 1989 and the other in 1992. Smith v.
Commissioner, 92 T.C. 1349 (1989); Kelley v. Commissioner, T.C.
Memo. 1993-495. Respondent filed his final brief in the pre-
TEFRA Tax Court litigation on August 14, 1992.5 Negotiations
regarding the terms of the settlement of the TEFRA Swanton
programs then restarted and continued until September 1993. The
final terms of settlement allowed the investors to deduct half
their cash investments, and subjected them to increased interest
under section 6621(c).
In late 1993, Ms. Sullivan began working on the
implementation of the basis of settlement for the TEFRA
partnerships. Although other IRS employees helped her
occasionally, Ms. Sullivan was generally the only IRS employee
assigned to the task of implementing the basis of settlement.
The settlement required her to draft closing agreements with
settlement numbers for each of the 37 Redwood partners, including
5 The Tax Court docket entry sheet for Kelley v.
Commissioner, supra, docket No. 34982-85, shows this date.
Respondent filed a notice of intent not to file a surrebuttal
brief on Sept. 30, 1992.
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