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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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