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filing penalty. The IRS also abated $185.51 of the assessed
interest. These abatements resulted in a credit of $1,304.16 in
favor of petitioner, which was applied to his outstanding
liabilities for 1993.
Revenue Agent Brian Rausch (Rausch) began an examination of
other aspects of petitioner’s 1995 income tax return on
December 31, 1997. Connie Stone (Stone), petitioner’s sister and
a resident of Virginia, represented petitioner. Stone falsely
represented that she was licensed as a certified public
accountant. The examination focused on Schedule C, Profit or
Loss From Business, deductions claimed by petitioner. During the
examination, Stone requested that petitioner’s address be changed
to her address in Henry, Virginia. The IRS entered this change
into its records during the week of August 16, 1998. On
August 18, 1998, the IRS received petitioner’s 1997 Federal
income tax return, which was timely filed pursuant to an
extension of time. This return bore the Woodside address. Its
receipt caused the IRS again to change its records, during the
week of October 25, 1998, to reflect that petitioner’s address
was once again the Woodside address.
At the end of November 1998, petitioner moved from the
Woodside address to Portola Valley, California. He submitted a
mail forwarding request to the U.S. Postal Service reflecting his
move.
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