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