Charles T. and Joan B. Phillips - Page 8

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          result of her own efforts in locating petitioner, she believed              
          the Brownway address to be his current address.                             
               On February 24, 1993, Group Manager Ronald W. Hopper mailed            
          a letter prepared by Revenue Officer Mills to petitioner at the             
          Brownway address.  The letter informed petitioner that the                  
          Internal Revenue Service proposed to assess against him a penalty           
          under section 6672 and that, if he did not agree, he should                 
          contact her within 10 days with additional information to support           
          his position.  The letter also informed petitioner that he had a            
          right to appeal the determination within 30 days of the date of             
          the letter, and, if Revenue Officer Mills did not hear from him,            
          the penalty would be assessed against him.  Petitioner did not              
          respond to the February 24, 1993, letter.                                   
               On March 19, 1993, Revenue Officer Mills received via fac-             
          simile, two powers of attorney from a certified public accountant           
          (C.P.A.) representing petitioner and Charles T. Phillips, P.C.              
          The powers of attorney listed the Brownway address as the peti-             
          tioners' current address.  Revenue Officer Mills received no                
          other information from petitioner, and, in June 1993, Revenue               
          Officer Mills closed the audit of Charles T. Phillips, P.C., and            
          recommended a section 6672 assessment against petitioner for the            
          employment tax liabilities of the corporation.  Although Revenue            
          Agent Mills believed the Brownway address was petitioners'                  
          current address, she did not update respondent's computer files             






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