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All three copies of the October 6 notice were returned to
respondent. The first carried a U.S. Postal Service (Postal
Service) stamp: “Box Closed, No Forwarding Order”; the second
carried a Postal Service stamp: “Return to Sender, Unclaimed”.
The third was returned unopened, under cover of a letter from
Pies that stated that he did not represent petitioner.
Petitioner’s Counsel
Initially, Pies represented petitioner in connection with
Price’s examination of petitioner’s 1991 tax year; later, that
representation was extended to include Price’s examination of the
years in issue. A Form 2848, Power of Attorney and Declaration
of Representative, appointing Pies petitioner’s attorney in fact
for purposes of income tax matters for 1985 through 1990 was
executed on behalf of petitioner by petitioner’s president,
Michael V. Jennings (Jennings), on March 21, 1994.
On August 23, 1994, Jennings hired another attorney,
Robert M. Levin (Levin), to represent petitioner before the
Internal Revenue Service in connection with income tax matters
for 1985 through 1991. On September 1, 1994, Levin wrote to the
Richmond, Virginia, District Office of the Internal Revenue
Service, and requested the release of certain documents pursuant
to the Freedom of Information Act, 5 U.S.C. sec. 552 (1994),
including documents relating to Price’s examination of
petitioner’s 1985 through 1991 tax years. Included with Levin’s
request was a Form 2848, Power of Attorney and Declaration of
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Last modified: May 25, 2011