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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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