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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
Landvogt.
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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