William and Penny Landvogt - Page 2

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          6404(h) and Rule 280.1  The issue for decision is whether                   
          respondent’s denial of petitioners’ claim for abatement of                  
          interest was an abuse of discretion.                                        
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated.  We incorporate the            
          stipulated facts into our findings by this reference.                       
          Petitioners resided in Janesville, Wisconsin, at the time of                
          filing the petition.  References to petitioner refer to Penny               
               In a letter dated June 14, 1994, respondent notified                   
          petitioners that their 1992 joint Federal income tax return had             
          been selected for audit.  Respondent later expanded the audit to            
          include petitioners’ 1993 and 1994 returns.  During the audit of            
          petitioners’ 1992, 1993, and 1994 returns, respondent’s                     
          examination focused on whether petitioners engaged in their                 
          horse-breeding operation for profit pursuant to section 183.                
               Additionally, in the June 14, 1994, letter, respondent                 
          requested a meeting with petitioners in Janesville, Wisconsin, on           
          July 12, 1994, in order to review petitioners’ records.  In a               
          reply letter dated June 21, 1994, petitioner requested that                 
          respondent’s auditor move the audit to Madison, Wisconsin, and              
          enclosed a Form 2848, Power of Attorney and Declaration of                  

               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code as amended, and all Rule references are           
          to the Tax Court Rules of Practice and Procedure.                           

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Last modified: May 25, 2011