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year. The notice was sent to Starvest at its Tierra Verde,
Florida, address and to Allen Swartz, to whom Starvest had
granted a power of attorney. Subsequent to issuance of the
notice of deficiency, Agent Traum issued a letter to Mario Boon,
president of Starvest, at his address in The Netherlands,
informing him of the issuance of the notice of deficiency and
providing him with a copy of the audit report. The letter
indicated that the notice of deficiency had been sent to
Starvest's corporate address in Tierra Verde, Florida. The
letter also indicated that Allen Swartz had reviewed the audit
report.
Jacques de Bruijn retained the law firm of Gibbs and Runyan
(Gibbs) to represent Starvest in matters relating to the 1997
notice of deficiency. Gibbs filed a petition in the name of
Starvest with this Court on August 12, 1997, for a
redetermination of the taxes determined in the 1997 notice of
deficiency. That petition was filed as docket No. 16948-97.
In May 1998, Gibbs filed a motion to withdraw as Starvest's
counsel. In the motion, which was granted, Gibbs represented
that Jacques de Bruijn was Starvest's president, and that all
future correspondence should be addressed to him. Subsequently,
on June 18, 1998, Gibbs filed what was styled as a status report
amending some of the statements made in the motion to withdraw.
Gibbs represented that, while Mr. de Bruijn had originally
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