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agrees with and adopts the opinion of the Special Trial Judge,
which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on respondent's Motion to Dismiss for Lack of
Jurisdiction. The facts pertinent to the disposition of this
matter are summarized below.
On August 10, 1994, Beatrice Appiah (petitioner) and her
estranged husband, Francis Appiah, executed a Form 2848 (Power of
Attorney and Declaration of Representative) appointing William G.
Davidson III as their attorney in fact regarding their Federal
income tax liability for the taxable years 1989, 1990, 1991, and
1992.
On January 10, 1995, petitioner executed a Form 8822 (Change
of Address) indicating that her address was changing from 11700
Old Columbia Pike, #708, Silver Spring, Maryland 20904 (the
Silver Spring address) to P.O. Box 17, Asankrangwa, Ghana, West
Africa (the Ghana address).2 The Ghana post office box belongs
to petitioner's parents. Petitioner traveled to Ghana on January
11, 1995, where she stayed with her parents until she returned to
the Silver Spring address on March 30, 1995.
On April 14, 1995, respondent mailed duplicate original
joint notices of deficiency to petitioner and her estranged
2 The record does not disclose the exact date when
petitioner filed her Form 8822 with the Internal Revenue Service.
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