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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
cases.
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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Last modified: May 25, 2011