James A. and Muriel M. Andrews - Page 5

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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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Last modified: May 25, 2011