- 8 - result of her own efforts in locating petitioner, she believed the Brownway address to be his current address. On February 24, 1993, Group Manager Ronald W. Hopper mailed a letter prepared by Revenue Officer Mills to petitioner at the Brownway address. The letter informed petitioner that the Internal Revenue Service proposed to assess against him a penalty under section 6672 and that, if he did not agree, he should contact her within 10 days with additional information to support his position. The letter also informed petitioner that he had a right to appeal the determination within 30 days of the date of the letter, and, if Revenue Officer Mills did not hear from him, the penalty would be assessed against him. Petitioner did not respond to the February 24, 1993, letter. On March 19, 1993, Revenue Officer Mills received via fac- simile, two powers of attorney from a certified public accountant (C.P.A.) representing petitioner and Charles T. Phillips, P.C. The powers of attorney listed the Brownway address as the peti- tioners' current address. Revenue Officer Mills received no other information from petitioner, and, in June 1993, Revenue Officer Mills closed the audit of Charles T. Phillips, P.C., and recommended a section 6672 assessment against petitioner for the employment tax liabilities of the corporation. Although Revenue Agent Mills believed the Brownway address was petitioners' current address, she did not update respondent's computer filesPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011