- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011