Robert G. Honts - Page 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                                        
                  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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