- 3 - TEA items and determined deficiencies and additions to tax for 1978, 1979, 1981, and 1982. On November 3, 1986, petitioners filed a petition with this Court seeking a redetermination of their tax liabilities for 1978, 1979, 1981, and 1982. Petitioners’ case was assigned to a group of cases collectively referred to as the Barrister Books project, hereinafter sometimes referred to as Barrister. Andrew M. Winkler (hereinafter sometimes referred to as Winkler) served as lead counsel for the Commissioner in the Barrister cases. Sometime around 1986, the Commissioner extended a uniform settlement offer to any Barrister investor. The Commissioner withdrew the offer on or about May 16, 1989. In the spring of 1993, the Commissioner renewed the earlier settlement offer. The task of processing the settlement of the Barrister cases fell to Winkler and Elmer Craig (hereinafter sometimes referred to as Craig), an Appeals officer in respondent’s Louisville, Kentucky, office, hereinafter sometimes referred to as the Louisville office. Winkler and Craig generally processed the Barrister cases–-including petitioners’ case--in taxpayer alphabetical order. In the spring of 1993, the Commissioner’s Appeals Office in Cincinnati, Ohio (hereinafter sometimes referred to as the Cincinnati office), learned of the Barrister case settlements that Winkler and Craig were processing. At that time, thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011