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connection with a 4-count felony indictment handed down by a
Federal grand jury. The indictment alleged that Mr. Amigron, a
former IRS revenue officer, falsely claimed to be a certified
public accountant, and an enrolled actuary, and that he knowingly
used false Social Security numbers on tax documents.8
D. Petitioner’s Amended Returns for 1985 and 1986
On September 15, 1995, more than 6 years after respondent
had assessed the deficiency and additions to tax for 1985 and
nearly 5 years after respondent had assessed the deficiency and
additions to tax for 1986, respondent’s Problem Resolution Office
in Little Rock, Arkansas, sent petitioner a letter enclosing a
copy of the notice of deficiency for 1986.
One week later, on September 22, 1995, petitioner executed
Form 2848, Power of Attorney and Declaration of Representative,
naming John H. Peterson (Mr. Peterson), an attorney, and Robert
M. Magness (Mr. Magness), a certified public accountant, as his
representatives with respect to his Federal income tax
liabilities for 1985, 1986, and 1993.
On November 6, 1995, Mr. Peterson sent a letter to
respondent enclosing an amended income tax return (Form 1040X)
for 1985 for petitioner. The amended return, which was signed on
behalf of petitioner by Mr. Magness, reduced taxable income (as
8 The record does not disclose the disposition of the
indictment.
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