Robert James Jaffe - Page 15

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          period May 8, 1992, through April 15, 1999.  We therefore must              
          review the events that occurred after May 8, 1992, to determine             
          whether respondent abused his discretion.                                   
               B.  May 9, 1992, Through September 1993                                
               From May 9 to August 14, 1992, respondent was involved in              
          litigation before this Court concerning the pre-TEFRA Swanton               
          programs.  In accordance with our holding above, it was not an              
          abuse of discretion for respondent to deny interest abatement for           
          that period.  See Lee v. Commissioner, supra at 150.                        
               After the completion of the pre-TEFRA Tax Court litigation,            
          Ms. Sullivan negotiated with counsel for the TEFRA Swanton                  
          programs regarding the final terms of settlement until September            
          1993.  The TEFRA Swanton settlement work was added to Ms.                   
          Sullivan’s normal caseload.  According to her testimony, because            
          she was not assisted by any other attorney, she could not                   
          finalize the terms of settlement while briefing the pre-TEFRA               
          cases.  The settlements could have been completed more quickly if           
          more than one person had regularly been working on them.                    
          Arguably, respondent made a managerial error when he assigned               
          only one employee to handle the settlement of all of the TEFRA              
          partnerships.  This managerial decision contributed to the delay            
          in the resolution of petitioner’s case after the overall                    
          settlement was reached.                                                     








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