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received from their farm corporation in each of those years.
These are the same adjustments that respondent determined in
the notice of deficiency which is the subject of this case.
As set forth in the 30-day letter sent to them, petitioners
had the right to appeal the proposed adjustment to the
Appeals Office. See sec. 601.106(b), Statement of
Procedural Rules. Petitioners chose not to pursue an
administrative appeal within the Internal Revenue Service
of the adjustments proposed in the 30-day letter.
The regulations promulgated under section 7430 discuss
the circumstances in which the administrative remedies
available within the Internal Revenue Service shall be
deemed to have been exhausted. See sec. 301.7430-1, Proced.
& Admin. Regs. Generally, under those regulations a party
will not be deemed to have exhausted the administrative
remedies with respect to any tax matter for which an Appeals
Office conference is available under sections 601.105 and
601.106, Statement of Procedural Rules, unless the party
participates in an Appeals Office conference before filing
a petition in the Tax Court. See sec. 301.7430-1(b)(1)(i),
Proced. & Admin. Regs.
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