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2848, Power of Attorney and Declaration of Representative,
executed by petitioners giving power of attorney to Mr.
Bezkorowajny. (We will refer to the letter as the March 5 letter
and the power of attorney form as Form 2848.) The Form 2848
contained the following preprinted sentence: “Notices and other
written communications will be sent to the first representative
listed in line 2.” This sentence was altered to read as follows:
“Notices and other written communications will be sent to the
taxpayer listed in line 1. No copies to be sent to
Representative stated above.” Line 1 of the Form 2848 contained
petitioners’ names and the Box 227 address.
According to Mr. Bezkorowajny, a certified public accountant
and former IRS Appeals officer, he hand-delivered the two
documents to the Taxpayer Service Center in Brooklyn in order to
comply with Rev. Proc. 90-18, 1990-1 C.B. 491, 492, which
contains the following instructions:
If a taxpayer no longer wishes the address of record to
be the one shown on the most recently filed return,
* * * clear and concise written notification of a
change of address must be sent to the Internal Revenue
Service Center serving the taxpayer’s old address or to
the Chief, Taxpayer Service Division in the local
district office. * * *
Rev. Proc. 90-18, supra, also provides as follows:
If a Service employee contacts a taxpayer in connection
with the filing of a return or an adjustment in the
taxpayer’s account, the taxpayer may provide clear and
concise written notification of a change of address to
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