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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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