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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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