Joseph M. Inman - Page 3

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            petitioner filed a petition with this Court alleging that                                     
            respondent had erroneously disallowed the $17,862 claimed loss.                               
                  After the petition was filed in this case, from November of                             
            1992 through the summer of 1993, petitioner failed to respond to                              
            correspondence from respondent’s Appeals Office, to appear at                                 
            conferences with respondent’s trial counsel, or to otherwise                                  
            provide respondent with information that respondent had                                       
            requested.  During this time, Dragna attempted to represent                                   
            petitioner before respondent’s Appeals Office and respondent’s                                
            District Counsel's Office.  Petitioner and Dragna, however, were                              
            repeatedly notified that respondent could not locate a POA on                                 
            file for Dragna.  Respondent, however, did provide to petitioner                              
            answers to certain questions raised by Dragna with respect to the                             
            basis for the notice of deficiency and to other matters.                                      
                  In September of 1993, a month before this case was scheduled                            
            for trial, petitioner mailed to respondent documents regarding                                
            the deductibility of the $17,862 claimed farming loss.  The                                   
            documents generally related to petitioner’s purchase in 1982 of a                             
            residence and a 20-acre parcel of real property in Copperopolis,                              
            California.  None of the documents, however, corroborated that                                
            petitioner was engaged in any type of farming activity.                                       
            Respondent reviewed those documents but reasonably determined                                 
            that they did not establish that petitioner was entitled to                                   
            deduct the claimed farming loss.                                                              






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