- -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