- 7 - 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 PhiladelphiaPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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