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No expenses have been incurred since the purchase
of the land which do not specifically relate to
the use of the property as prescribed by the CRP
contract. Taxpayers have not incurred costs of a
nature which are only for the future use of their
farm after they are no longer being paid by the
CRP.
In the protest letter petitioners requested that the matter be
transferred to the appropriate Appeals officer if the Examination
Division did not agree with petitioners’ position. In addition
to a Form 2848, Power of Attorney and Declaration of
Representative, and the examination report, the protest letter
listed as enclosures the following:
CRP Contract
Letter from ASCS Office dated 3/16/87
Letter from ASCS Office dated 8/8/90
Letter from ASCS Office dated 9/7/90
Letter from ASCS Office dated 7/20/93
Discussion of CRP payments from the “1992 Farm Income
Tax Workbook”
Page 17 of IRS Publication 225
The letters from the ASCS Office listed above refer to the farm
status determination letters petitioners received annually from
the Cascade County ASCS.
Sometime in September 1995, respondent requested that
petitioners sign a waiver of the limitations period. In a letter
dated October 2, 1995, to Mark Murray, Operations Manager at
respondent's Great Falls office, petitioners declined to sign the
waiver, stating:
there is no need for an extension of time. This matter
was appealed to higher authority three months ago. It
should not even be in your office. It especially
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