John G. Goettee, Jr. and Marian Goettee - Page 4

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         Cincinnati office Appeals officers’ caseloads were about half of             
         their normal caseloads.  The chief of the Cincinnati office, the             
         associate chief (Paul R. Becker, hereinafter sometimes referred              
         to as Becker), and Appeals Officer Fran Rowland (hereinafter                 
         sometimes referred to as Rowland) went to the Louisville office              
         to discuss with Winkler and Craig the possibility of the                     
         Cincinnati office’s processing some of the Barrister case                    
         settlements.  By the end of the meeting, it was decided that the             
         Cincinnati office would take some 200 of the Barrister cases.                
         Winkler remained responsible for executing Tax Court decision                
         documents on behalf of the Commissioner in Barrister cases.  The             
         Cincinnati office picked up the cases from the Louisville office             
         in June of 1993.                                                             
              The number of cases transferred to the Cincinnati office,               
         coupled with their complexity, created the need for Craig to                 
         conduct an all-day training session about how to process the                 
         settlement of the cases.  The need for a training session to                 
         become able to settle a case was not typical.                                
              About July of 1993, about 75 cases, including petitioners’              
         case, were assigned to Rowland.                                              
              Appeals officers in the Cincinnati office managed multiple              
         priorities while they processed the settlement of the Barrister              
         cases.  Cases nearing the end of the limitations period, and Tax             
         Court cases calendared for trial in Cincinnati and Columbus,                 

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