John G. Goettee, Jr. and Marian Goettee - Page 6

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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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