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resolution.” In another letter to John Rigler, dated April 24,
1996, petitioners further requested that they be given more
information from respondent's “technical manual” regarding “the
administration of the IRS operations department for case
preparation”.
On May 3, 1996, petitioners retained Thomas E. Towe to
represent them in this case.6
In a letter dated May 22, 1996, John Rigler responded to
petitioners’ April 12, April 13, and April 24 letters. Mr.
Rigler stated:
You clearly have been frustrated in your efforts to
find out what “court rulings” were referred to in the
examination report proposing an adjustment to rental
income and expenses on your 1990 income tax return. To
rectify this problem, an IRS attorney researched this
matter and provided me with the following information
to give you:
Under the Conservation Reserve Program (CRP), the
farmer receives a yearly rental payment from the
government in return for implementing a ten year
conservation program. The farmer is barred from
harvesting any crops from the land or utilizing it
for grazing purposes. Other than planting cover
and eradicating noxious weeds, the land must be
left alone. See In re Matter of Lundell Farms, 86
B.R. 582, 584 (Bankr.W.D.Wis. 1988); 7 C.F.R.
section 704.1 et seq.
In In re Way, 120 B.R. 81, 82 (Bankr.S.D.Tex.
1990), the Court explained CRP as follows: “Under
farm programs like the [CRP], owners and operators
6 On Mar. 6, 1997, Mr. Towe filed a motion to withdraw as
counsel of record for petitioners. Mr. Towe’s motion was granted
on Mar. 20, 1997.
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