Leon S. Malachinski - Page 3




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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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