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Sometime during 1996 or 1997, Appeals Officer McNamee agreed
to provide petitioners with additional time in which to
demonstrate that the horse-breeding operation could be
profitable. In a letter to petitioners dated April 10, 1998,
Appeals Officer McNamee noted that he had not received
correspondence from petitioners or their representatives for
“awhile” and drew the conclusion that the horse-breeding
operation had not met petitioners’ profitability projections.
Appeals Officer McNamee also gave petitioners 10 days to respond
to an enclosed settlement proposal, which petitioners did not
accept.
On December 7, 1998, respondent issued a notice of
deficiency to petitioners. On February 5, 1999, petitioners
filed a petition with this Court contesting the deficiencies.
Shortly thereafter, in a letter dated February 15, 1999, Mr.
Grams notified Appeals Officer McNamee that he no longer would
serve as petitioners’ representative.
Petitioners’ deficiency case was tried on December 6, 1999,
in Milwaukee, Wisconsin. This Court decided in Landvogt v.
Commissioner, T.C. Summary Opinion 2000-239, filed November 3,
2000, that petitioners did not engage in their horse-breeding
operation for profit in 1992, 1993, and 1994. On November 30,
2000, respondent sent to petitioners Respondent’s Computation for
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Last modified: May 25, 2011