- 3 - 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 aPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011