3
Time To File U.S. Individual Income Tax Return) from petitioner
for tax year 1987. Respondent granted the request, extending the
filing date to October 15, 1988. Petitioner filed his 1987 joint
Federal income tax return on March 28, 1989, on which he claimed
a net operating loss (NOL) deduction in the amount of $105,332.
On October 10, 1990, petitioner filed amended returns (Forms
1040X) for years 1984 and 1986 to carry back the unused portion
of the 1987 NOL.
In November 1991, revenue agent Eduardo Lizcano (Agent
Lizcano) commenced an examination of petitioner's 1987 return.
On December 18, 1991, pursuant to his request, Agent Lizcano
received a Form 2848 (Power of Attorney and Declaration of
Representative) from petitioner appointing his accountants David
E. Erickson, Jr. (Mr. Erickson), and Robin C. Demel (Mr. Demel),
located at 1201 W. 24th St., Suite 200, Austin, Texas 78705, as
his attorneys-in-fact for taxable year 1987. Line 7 of the Form
2848 provides:
Notices and Communications.--Notices and other written
communications will be sent to the first representative
listed in line 2.
Petitioner listed his home address on the Form 2848 as 13302
Mansfield Drive, Austin, Texas 78732 (the Mansfield address).
At respondent's request, petitioner also executed and filed
Forms 2848 for taxable years 1988 through 1991 for himself, in
addition to Forms 2848 for Bandera Properties, Inc., Bob Honts
Properties, Inc., and Masa Menos, Inc.
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