William and Penny Landvogt - Page 6

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          Entry of Decision and a proposed Decision (the Rule 155                     
               At this time, petitioners hired Donald Bailey, a certified             
          public accountant, to assist them.  While working on the Rule 155           
          computation, Mr. Bailey discovered that respondent’s                        
          determination failed to include as Schedule A, Itemized                     
          Deductions, property taxes formerly claimed by petitioners on               
          their Schedules F, Profit or Loss from Farming.  Once informed of           
          the matter, respondent adjusted petitioners’ liabilities                    
               After several sets of revisions, on February 28, 2001,                 
          petitioners sent to respondent the Rule 155 computation and                 
          indicated in an accompanying letter that petitioners did not                
          agree to the interest amounts.  On March 19, 2001, respondent               
          submitted the Rule 155 computation to this Court,2 and, on April            
          13, 2001, this Court entered a decision, upholding the                      
               On July 31, 2001, respondent assessed the deficiencies and             
          assessed interest in the amounts of $4,557.32 for 1992, $4,775.59           
          for 1993, and $4,144.29 for 1994.  Petitioners filed Form 843,              

               2On Mar. 23, 2001, this Court issued a Notice of Filing of             
          Computation under Rule 155, advising petitioners to file their              
          notice of objection by Apr. 13, 2001.  Petitioners filed                    
          Petitioners’ Computation for Entry of Decision and Notice of                
          Objection to Respondent’s Proposal on Apr. 6, 2001, objecting               
          solely to the amount of interest shown as due.                              

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