Robert G. Honts - Page 11

            notices to representatives be a mere courtesy, it would have been                              
            a simple matter to express this intent in clear language on the                                
            Form 2848.  The language of the power of attorney at issue is                                  
            altogether too plain to give it a meaning contrary to its                                      
            unambiguous terms.  We think it is clear that the power of                                     
            attorney directing that "notices and all other communications                                  
            will be sent" to petitioner at the address of his accountants was                              
            sufficient to render that address petitioner's "last known                                     
            address" for the purpose of his 1987 income tax liability.                                     
                  In light of all of the surrounding facts and circumstances,                              
            we find it unreasonable for respondent not to have informed                                    
            petitioner's representatives of the issuance of the notice of                                  
            deficiency.  It would have been a simple task to notify the                                    
            representatives in light of Agent Lizcano's continued presence                                 
            at, and communication with, their office.  Based on the reasoning                              
            of Ward v. Commissioner, 907 F.2d 517 (5th Cir. 1990), revg. 92                                
            T.C. 949 (1989), the Commissioner is under an obligation to                                    
            verify an address with a representative in situations where the                                
            Commissioner has a working relationship with the representative.                               
            This is true regardless of whether notices and communications are                              
            required to be sent to the representative.  See Pomeroy v. United                              
            States, 864 F.2d 1191, 1194-1195 (5th Cir. 1989).  As such,                                    
            respondent was aware that the address of petitioner's                                          
            representatives was the address to which petitioner intended all                               
            notices and communications to be sent with respect to not only                                 

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