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1988-91 5/19/95 6/30/96
1988-91 1/22/96 12/31/96
Forms 2848
On April 12, 1993, Gary Powers executed Form 2848, Power of
Attorney and Declaration of Representative, identifying the
taxpayer as "Hibiscus Life Insurance Co. & Subsidiary" and
appointing David L. Veeder and John K. Cassil as Hibiscus'
attorneys in fact for the taxable years 1989 and 1990. On July
20, 1993, Gary Powers executed separate Forms 2848 for Hibiscus
and petitioner appointing Messrs. Veeder and Cassil as Hibiscus'
and petitioner's attorneys in fact for the taxable year 1991. On
September 20, 1993, Gary Powers executed Form 2848, identifying
the taxpayer as "Hibiscus Life Insurance Co. & Subsidiary",
appointing Messrs. Veeder and Cassil as Hibiscus' attorneys in
fact for the taxable year 1988.4
30-Day Letters
On April 12, 1993, the District Director issued separate 30-
day letters to Hibiscus and petitioner (along with separate
revenue agent reports (RAR's)) proposing adjustments to their
respective tax liabilities for 1988, 1989, and 1990 on the ground
that Hibiscus and petitioner were not entitled to file
4 Gary Powers executed the Forms 872 that were executed on
Jan. 27, 1992, and July 1, 1993, and David L. Veeder executed the
remainder. Gary Powers testified at the hearing of this matter
that in executing the Forms 872, he intended to extend the period
of limitations for the Hibiscus consolidated group.
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