Robert James Jaffe - Page 13

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               Activity                                Date                           
          Petitioner files his 1983               Apr. 15, 1984                       
          return                                                                      
          Petitioner files his 1984               Aug. 12, 1985                       
          return                                                                      
          Pre-TEFRA test cases begin              1989                                
          in Tax Court                                                                
          Ms. Sullivan is assigned to             May 1991                            
          Swanton programs                                                            
          Tentative basis of settlement           September 1991                      
          is reached for TEFRA                                                        
          Swanton programs                                                            
          Respondent files last brief in          Aug. 14, 1992                       
          pre-TEFRA Swanton Tax Court                                                 
          litigation                                                                  
          Final agreement on terms of             September 1993                      
          settlement is reached.                                                      
          Asher’s TMP signs closing               July 9, 1997                        
          agreement                                                                   
          Respondent countersigns                 Dec. 10, 1998                       
          Asher’s closing agreement                                                   
          Respondent issues notice of             Aug. 20, 1999                       
          adjustment to petitioner                                                    
               A.  April 15, 1984, Through May 8, 1992                                
               We held in Beagles v. Commissioner, T.C. Memo. 2003-67, that           
          the Commissioner was not erroneous or dilatory in performing a              
          ministerial act with respect to the Swanton programs between                
          April 15, 1984, and May 8, 1992.  See also Deverna v.                       
          Commissioner, T.C. Memo. 2004-80.  We will briefly describe the             
          events that support this holding.                                           






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