Thomas Frederick Dadian and Lois Ann Dadian - Page 4

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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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