John G. Goettee, Jr. and Marian Goettee - Page 3

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         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, the                   






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