- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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