- 3 - Representative, designating Nell Ray as petitioners’ representative. Pursuant to petitioner’s request, respondent transferred the case to the Madison, Wisconsin, office. After receiving respondent’s letter dated September 6, 1994, proposing a conference in Madison, Wisconsin, Ms. Ray called the auditor, Kenneth Gernetzke, and scheduled a conference for October 4, 1994. Subsequently, Mr. Gernetzke canceled the October 4, 1994, conference, rescheduled the conference for October 28, 1994, canceled the October 28, 1994, conference, and then rescheduled the conference for November 2, 1994. Mr. Gernetzke and Ms. Ray attended the November 2, 1994, conference. In addition to the conference held on November 2, 1994, Ms. Ray and Mr. Gernetzke met to review petitioners’ records on November 7, 1994, before petitioners replaced Ms. Ray with a new representative, Michael Ellsworth, on December 3, 1994. At this point, Mr. Ellsworth requested time to “assemble additional information” regarding petitioners’ case. Mr. Ellsworth and Mr. Gernetzke eventually discussed the case over the telephone on June 28, 1995. In a report issued on August 28, 1995, respondent determined that petitioners’ horse-breeding operation was not an activity engaged in for profit and disallowed the related losses petitioners claimed on Schedule C, Profit or Loss From Business. The Milwaukee Appeals Office (Appeals) sent a letter toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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