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regarding petitioner. When Ms. Meuse checked the computer system
to see whether Mr. Vecchio had a power of attorney which would
enable her to discuss petitioner's case with him, she discovered
he had no power of attorney. Ms. Meuse called Mr. Vecchio to let
him know that she needed a power of attorney before she could
give him any information about petitioner. The same day that Ms.
Meuse received petitioner's 1987 return, Ms. Meuse mailed to
petitioner, for petitioner's ex-wife to sign under penalties of
perjury, a declaration that, to her knowledge, the information on
the return was true. The declaration was mailed to petitioner
because Mr. Vecchio did not have a power of attorney on file.
On March 12, 1997, Mr. Vecchio told Ms. Meuse that he would,
by facsimile copy, send a power of attorney later that day, but
Ms. Meuse did not receive it. Four or five days later, she again
contacted Mr. Vecchio, saying that she needed the power of
attorney in order to give him information. Three or four days
later, Ms. Meuse again called Mr. Vecchio, who insisted that he
had already sent a power of attorney to her. When she did not
receive the power of attorney, she called him again and asked him
to resend the power of attorney, which she received.
Once Ms. Meuse received Mr. Vecchio's power of attorney, she
informed him that she could not process the 1987 return without
petitioner's ex-wife's signature. She also told him that if she
did not receive it within 10 days, she would have to change the
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