- 13 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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