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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, upon
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