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years ending May 31, 1992, 1993, 1994, 1995, and 1996.3
Subsequent to receiving the Tax Information Authorization, Agent
Traum issued a letter and copy of the form to Mr. de Bruijn. The
letter explained that the Tax Information Authorization allowed
Mr. de Bruijn to inspect and receive confidential information
relating to Starvest. The letter pointed out, however, that Mr.
de Bruijn could not sign documents on behalf of the corporation
unless a power of attorney was secured. Throughout the remainder
of the audit, Agent Traum continued to deal with Mr. de Bruijn as
Starvest's representative.
In November 1996, Warren Knaust resigned as Starvest's
resident agent. Starvest failed to appoint another registered
agent. On March 14, 1997, Starvest was administratively
dissolved by the State of Florida for its failure to have a
registered agent as required by Florida law.
On May 15, 1997, IRS issued a notice of deficiency (1997
notice of deficiency) to petitioner for its May 31, 1992, tax
3 Form 8821, Tax Information Authorization, is
authorization to IRS by a taxpayer designating any individual,
corporation, firm, organization, or partnership to inspect and/or
receive any confidential information regarding the taxpayer in
any office of the IRS with regard to the tax and for the years or
periods listed in the form. Form 8821, however, does not
constitute authority to such designee to execute waivers,
consents, closing agreements, or to otherwise represent the
taxpayer before the IRS. Form 2848, Power of Attorney and
Declaration of Representative, is the necessary form for such
purposes.
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