12 the year 1987, for which a power of attorney was filed, but also for 1984 and 1986. Respondent argues that she was not permitted to mail the notice to petitioner's accountants because, in doing so, she would have committed an unauthorized disclosure of taxable years 1984 and 1986. Agent Lizcano testified that he requested that petitioner execute powers of attorney for 1984 and 1986, but that petitioner would not do so. Revenue agent John Robert Rossmiller testified that it was not IRS policy to prepare separate notices for separate tax years in order to prevent unauthorized disclosures. During the course of respondent's examination, Agent Lizcano requested, and petitioner provided, powers of attorney for tax years 1987 through 1991, in addition to powers of attorney for three related corporations. We find it difficult to accept that petitioner would have provided all of these powers of attorney, yet refused to provide the same for tax years 1984 and 1986. Furthermore, the only adjustments made to petitioner's 1984 and 1986 returns were due to the disallowance of petitioner's 1987 NOL. During his examination of the 1987 tax year, Agent Lizcano gave the accountants copies of petitioner's 1984 and 1986 amended returns after receiving permission to do so from petitioner. To now argue, as respondent does, that the notice of deficiency was not mailed to the accountants to avoid disclosure of this information is, at the very least, self-serving. Moreover, uponPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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