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Drive, Seal Beach, California, after the divorce. Petitioner
lived at that address until May 1994.
On August 17, 1992, petitioner and Mr. Kim signed a Form
2848, Power of Attorney and Declaration of Representative (power
of attorney), in favor of Mr. Dale Zuehls (Mr. Zuehls). The
power of attorney authorized Mr. Zuehls to perform any and all
acts that petitioner could perform with respect to her income tax
for the taxable years 1988 through 1990, including the authority
to execute any agreements or consents in connection with her tax
liabilities for the years 1988, 1989, and 1990. Petitioner
signed the form before Mr. Zuehls' name was listed as the
representative, but with the knowledge that she was hiring
someone to represent her before the Internal Revenue Service
(IRS) with respect to her tax matters. Petitioner was aware at
the time she executed the power of attorney that her tax
liabilities for 1988 and 1989 were being investigated.
Internal Revenue Agent Jackie Novella (Agent Novella) was
assigned to audit petitioner's and Mr. Kim's Federal income tax
liabilities for the years 1988 and 1989. Agent Novella dealt
primarily with Mr. Kim and Mr. Zuehls during the examination.
Petitioner did not involve herself in the audit, and she gave any
correspondence to her from the IRS to Mr. Kim unopened.
On November 17, 1992, Agent Novella sent by certified mail a
Form 872, Consent to Extend the Time to Assess Tax, with respect
to Federal income tax due with respect to petitioner's and Mr.
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