St. Joseph Lease Capital Corporation - Page 7

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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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