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Representative, appointing Levin petitioner’s attorney in fact
for purposes of income tax matters for 1985 through 1991. By its
terms, that power revoked all prior powers for the same matters
and years.
On November 2, 1994, Levin learned from a disclosure
specialist in the Richmond District Director’s office that the
October 6 notice had been sent. He asked if he could obtain a
copy, and he was referred to John Henry (Henry), the senior
reviewer in the Richmond District Quality Assurance Branch.
Levin contacted Henry, who agreed to send Levin a copy of that
notice. Henry did so by facsimile transmission, received in
Levin’s office on November 10, 1994. In so acting, Henry acted
to protect the interests of petitioner.
1993 Consolidated Return
On August 31, 1994, petitioner's parent corporation,
Financial Analytics Corp., sent its 1993 consolidated income tax
return to respondent's Philadelphia Service Center on Form 1120,
U.S. Corporation Income Tax Return. Attached to that Form 1120
was a Form 851, Affiliations Schedule. That Form 851 states that
petitioner's address is 218 North Lee Street, Suite 300,
Alexandria, Virginia, 22314 (the North Lee Street address).
Form 8822
On September 21, 1994, petitioner sent a Form 8822, Change
of Address, by overnight courier to respondent's Philadelphia
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