Joanne Soon Kim - Page 3

                                                  -  -3                                                     
            Drive, Seal Beach, California, after the divorce.  Petitioner                                 
            lived at that address until May 1994.                                                         
                  On August 17, 1992, petitioner and Mr. Kim signed a Form                                
            2848, Power of Attorney and Declaration of Representative (power                              
            of attorney), in favor of Mr. Dale Zuehls (Mr. Zuehls).  The                                  
            power of attorney authorized Mr. Zuehls to perform any and all                                
            acts that petitioner could perform with respect to her income tax                             
            for the taxable years 1988 through 1990, including the authority                              
            to execute any agreements or consents in connection with her tax                              
            liabilities for the years 1988, 1989, and 1990.  Petitioner                                   
            signed the form before Mr. Zuehls' name was listed as the                                     
            representative, but with the knowledge that she was hiring                                    
            someone to represent her before the Internal Revenue Service                                  
            (IRS) with respect to her tax matters.  Petitioner was aware at                               
            the time she executed the power of attorney that her tax                                      
            liabilities for 1988 and 1989 were being investigated.                                        
                  Internal Revenue Agent Jackie Novella (Agent Novella) was                               
            assigned to audit petitioner's and Mr. Kim's Federal income tax                               
            liabilities for the years 1988 and 1989.  Agent Novella dealt                                 
            primarily with Mr. Kim and Mr. Zuehls during the examination.                                 
            Petitioner did not involve herself in the audit, and she gave any                             
            correspondence to her from the IRS to Mr. Kim unopened.                                       
                  On November 17, 1992, Agent Novella sent by certified mail a                            
            Form 872, Consent to Extend the Time to Assess Tax, with respect                              
            to Federal income tax due with respect to petitioner's and Mr.                                




Page:  Previous  1  2  3  4  5  6  7  8  Next

Last modified: May 25, 2011