- 5 - 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 toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011