Robert G. Honts - Page 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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