Donald B. Hawksley - Page 6




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          deductions in the amount of $23,791.  Petitioner also attached to           
          his return a Schedule E, Supplemental Income and Loss.  On the              
          Schedule E, petitioner claimed net losses from two limited                  
          partnerships in the aggregate amount of $47,304, as follows:                

                    Partnership                 Loss Claimed                          
                    Barrington Park               $26,710                             
                    Southmark/Envicon              20,594                             
                    $47,304                                                           

               On April 24, 1989, respondent sent a letter to petitioner in           
          Romoland, California, notifying him that his 1986 return had been           
          selected for examination and requesting that he contact the                 
          Modesto, California office in order to schedule an appointment.             
               From June to October 1989, respondent was contacted on                 
          various occasions by Ralph “R.A.” Amigron (Mr. Amigron), who                
          claimed to be a certified public accountant and petitioner’s                
          representative under a power of attorney.5  However, respondent             
          did not have on file any power of attorney from petitioner naming           
          Mr. Amigron as petitioner’s representative.  Accordingly,                   
          respondent did not recognize Mr. Amigron as petitioner’s                    
          representative; rather, respondent undertook to send all                    
          correspondence directly to, and deal directly with, petitioner.             
               Having learned that petitioner may have moved from Romoland,           

               5  At some point in time before June 1989, petitioner had              
          hired Mr. Amigron as a sales representative for the company for             
          which petitioner worked as a manager.  Sometime thereafter,                 
          petitioner engaged Mr. Amigron to represent him before the IRS.             





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