Ex. F

MLS:DG:ABCoe:xyz
154-000-00
CMN 0000000 		[Date submitted to Section Front Office]

MEMORANDUM FOR [ACTING] ASSISTANT ATTORNEY GENERAL [NAME]

Re: Name of case v. United States
   Fed. Cl. No. 000-00 T   

RECOMMENDATION RE OFFER IN [PARTIAL] COMPROMISE

[OR]

RECOMMENDATION RE [PARTIAL] CONCESSION

Nature of suit:[Suit for refund of 1990 income tax, plus interest][1/]

[Suit to reduce to judgment assessment of estate tax of decedent dying 00/00/00]

Amount claimed by taxpayer:$000,000.00, plus interest
[Amount claimed by Government:][$000,000.00, plus interest]
Amount to be paid by Government:$000,000.00
Amount to be paid to Government:$000,000.00
Recommendations:

     District/Chief Counsel:

[Acceptance by letter dated __________]

[Rejection by letter dated ___________]

[Classified SOP by letter dated ___________]

     Trial Attorney:Acceptance
Taxpayer's representative:Name, Esquire
Firm, if any
Street Address
Suite number
City, State, Zip Code

QUESTIONS PRESENTED

TERMS OF OFFER [CONCESSION RECOMMENDED]

STATUTES AND REGULATIONS INVOLVED

STATEMENT

DISCUSSION

CONCLUSION


Respectfully submitted,

Abel B. Coe

1 / The offer covers non-suit years (txps) and involves $_________, as to which $________ is conceded by the Govennment.

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