Curtis and Mary Ettesvold - Page 9

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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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