- 19 - 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 appealsPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011