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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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