Barry and Debra Bulakites - Page 3

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               On April 14, 1997, respondent mailed a 30-day letter to                
          petitioners at the Guilford address.  In the 30-day letter,                 
          respondent notified petitioners of proposed changes to their tax            
          liability for 1994.                                                         
               On May 16, 1997, petitioners' accountant, Edward E. Pratesi            
          (Mr. Pratesi), wrote a letter to respondent's agent, apparently             
          in response to the 30-day letter.  Mr. Pratesi's letter stated              
          as follows:                                                                 
               Because our client Barry Bulakites * * * has relocated                 
               to Michigan, the enclosed letter was not received                      
               until recently.                                                        
               In accordance with my client's wishes, we request an                   
               appeal of the tax and related penalties.  The reason                   
               for the appeal is that certain documentation                           
               supporting a disallowed deduction must be located upon                 
               Mr. Bulakites' return to Connecticut.                                  
          Mr. Pratesi's letter made no mention of Mr. Bulakites' address              
          in Michigan.                                                                
               In the interim, on May 14, 1997, petitioners executed a                
          Form 2848 (Power of Attorney and Declaration of Representative)             
          appointing Mr. Pratesi as their attorney-in-fact regarding their            
          Federal income tax liabilities for the taxable years 1994, 1995,            
          and 1996.  Petitioners listed the Guilford address as their                 
          address on the Form 2848.                                                   
               Line 7 of the Form 2848 provides in pertinent part as                  
          follows:                                                                    
               Notices and communications.  Original notices and                      
               other written communications will be sent to you and a                 




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