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joint Federal income tax return for their taxable year 1980 on
April 15, 1981.
Late in 1982 or early in 1983, respondent’s agents called
petitioner with respect to the 1980 Federal income tax return.
Petitioner then sought the advice of Vincent Arnone, his tax
return preparer. Petitioner and Wynne granted a power of
attorney to Mr. Arnone and to attorney Eugene F. LaPorte on
March 31, 1983.
Wynne filed for divorce in March of 1983 but delayed telling
petitioner of the filing until approximately a month later.
On May 23, 1983, revenue agent Alan Neubauer sent a letter
addressed to petitioner and Wynne, requesting that they sign and
return an enclosed Form 872-A, Special Consent to Extend the Time
to Assess Tax, for their 1980 tax year. On or about June 8,
1983, the Internal Revenue Service received the Form 872-A, which
had been dated June 1, 1983, and which bore the handwritten names
of both petitioner and Wynne. An official of the IRS
countersigned the Form 872-A on June 8, 1983.
Three days later, on June 11, 1983, petitioner and Wynne
granted another power of attorney to John R. Ostrand, C.P.A., and
Stephen B. Mack, C.P.A. The power of attorney was originally
prepared on May 23, 1983.
On September 1, 1983, Wynne issued a separate power of
attorney naming as her representatives before the IRS two
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