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were sent to Brown and his wife. Between January 3 and
November 24, 1997, Brown signed the revised closing agreements
and returned them to District Counsel’s office. The agreements
had to be signed by Manhattan Appeals, however, and not by
District Counsel. The closing agreements were countersigned by
Manhattan Appeals and then returned to District Counsel’s office.
On November 24, 1997, after District Counsel’s office
received the signed closing agreements from Manhattan Appeals,
the Manhattan Associates decision document was sent to the Tax
Court. On December 2, 1997, a decision was entered in the
Manhattan Associates case by the Court under Rule 248(a) for 1982
through 1984. On March 2, 1998, the decision became final under
section 7481. The Manhattan Associates case was sent to
Manhattan Appeals for closing and assessment. The case was sent
to the controlling IRS service center for the Swanton coal
programs for processing and forwarded to the TEFRA unit of the
IRS service center where the taxpayers filed their returns so
that the taxpayers could be assessed.
On September 9, 1998, Forms 4549-A, Income Tax Examination
Changes, were sent to petitioner for 1984. On October 13, 1998,
Forms 4549-A were sent to petitioner for 1982. On October 29,
1998, Forms 4549-A were sent to petitioner for 1983.
As a result of the changes to petitioner’s account due to
the Manhattan Associates TEFRA proceedings, the IRS assessed
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