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maintenance of income. Therefore, taxable income is
decreased $3,622.00 for 1992 and $1,941.00 for 1994.
(c) Due to an increase in the amount of adjusted gross
income for 1993, as computed at Exhibit A, no amount of
net operating loss deduction is available to be carried
from 1993 to 1990. Consequently, the tentative
allowance for 1990 is recaptured in full.
In a letter dated March 18, 1996, petitioners wrote
respondent and again demanded “copies of all evidence and support
data previously requested”. Petitioners noted that their
previous requests for the “court rulings” referenced in Ms.
McConaughy’s report have been “ignored and denied by IRS action”,
and that the “previously requested data supporting the IRS
position” was required for the “effective presentation” of
petitioners’ case.
In a letter dated March 29, 1996, to John Rigler, Problem
Resolution Officer with respondent's Helena office, petitioners
again requested information regarding the “chain of command” for
respondent's Appeals Office. Petitioners stated that this
information was “necessary for the preparation of our defense in
seeking adjudication.”
Petitioners wrote another letter on April 23, 1996, to John
Rigler, again outlining their position for the “complaint before
the ombudsman” regarding the “professional protocol of the
appeals section actions.” Petitioners also requested the
“appeals division technical operations manual outlining one-by-
one the procedural steps required of IRS personnel in appeals
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