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October 26, 1995 to furnish data in support of IRS
argument(s) * * *.
In a letter dated January 8, 1996, petitioners again wrote
to Ms. Teichrow’s supervisor, Greg Loendorf. In this letter,
petitioners requested that Mr. Loendorf “see to it that some
responsible individual within your department furnishes us with a
list of personnel as it pertains to the Appeals Division 'chain
of command,' beginning with the name of the assigned appeals
officer all the way to the top.” Petitioners also claimed that
Ms. Teichrow “refused to provide the citations of law and/or
authority and support data” that petitioners had previously
requested.
As indicated, on February 29, 1996, respondent issued a
notice of deficiency to petitioners in which deficiencies in
their 1990, 1992, and 1994 Federal income taxes were determined.
Relevant for our purposes, the adjustments that gave rise to the
deficiencies were explained as follows:
(a) The $9,067.00 and the $10,024 shown on the 1992
and 1994 returns, respectively, as Schedule F farm
losses are not allowed because it has not been
established that any amount of loss was sustained in a
trade or business. However, certain of these
deductions are allowable as rental expenses, below.
Therefore, taxable income is increased $9,067.00 for
1992 and $10,024.00 for 1994.
(b) Of the losses addressed above, $3,622.00 for 1992
and $1,941.00 for 1994 were expended for the
production, maintenance or conservation of income. The
remainder of the losses are not allowable since they
were not sustained in a trade or business and were not
expended for the production, conservation or
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