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them to the Court for entry of decision. It ordinarily took
Winkler less than 1 hour to review and sign an average decision
document that did not have any problems. However, Winkler gave
priority to working on cases calendared for trial by the Court.
On November 24, 1993, Rowland sent to petitioners a
settlement letter. On December 2, 1993, petitioners’
verification information was sent to Rowland.
On October 26, 1994, Rowland mailed the settlement documents
to petitioners. Petitioners signed the decision document on
November 25, 1994, and mailed it to Rowland on December 14, 1994.
The decision document stated, in pertinent part:
It is further stipulated that, effective upon entry of
this decision by the Court, the petitioners waive the
restriction contained in I.R.C. � 6213(a) prohibiting
assessment and collection of the deficiencies in income tax
and additions to tax (plus statutory interest) until the
decision of the Tax Court has become final.
On December 23, 1994, Rowland prepared, signed, and sent to
Becker an appeals transmittal and case memorandum which outlined
the terms of the settlement of petitioners’ case.
On January 13, 1995, Becker signed and approved the appeals
transmittal and case memorandum. Becker then delivered
petitioners’ proposed decision document to the records office of
the Cincinnati office, which had 5 days to send the proposed
decision document to Winkler.
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Last modified: May 25, 2011