John G. Goettee, Jr. and Marian Goettee - Page 5

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         Ohio, were given a higher priority than the Barrister cases.                 
         Rowland typically did all of the service center claim cases–-                
         these, too, were given a higher priority than the Barrister                  
              Although Rowland’s caseload was about half her normal                   
         caseload in the spring of 1993, her caseload returned to normal              
         about the same time the Barrister cases were assigned to her.                
         Because of the increase in her workload, Rowland did not send any            
         settlement letters to any Barrister taxpayers until about                    
         September of 1993.                                                           
              The settlement letters (1) stated the terms of the                      
         settlement offer, (2) asked the recipients to submit to Rowland              
         copies of their canceled checks within 10 days so that she could             
         verify the recipients’ actual cash investment in the partnership,            
         and (3) stated that upon receipt of the verification information,            
         Rowland would send to the Barrister taxpayer computations which              
         showed the tax effects of the settlement offer to that taxpayer.             
              If a taxpayer accepted the settlement offer and returned the            
         signed decision document, then Rowland prepared and submitted to             
         Becker an appeals transmittal and case memorandum for his                    
         approval.  If Becker approved, then he signed the appeals                    
         transmittal and case memorandum and transmitted the settlement               
         documents to Winkler.  Winkler then reviewed the format and                  
         contents of the decision documents, signed them, and forwarded               

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