William and Penny Landvogt - Page 5

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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               
               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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