William and Penny Landvogt - Page 3

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          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 to                     

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