Starvest U.S., Inc. - Page 5

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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               

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