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representative. Mr. Mark had been petitioners’ accountant for
approximately 25 years. The Form 2848 was signed by petitioners
and Mr. Mark and dated October 6, 1993. The Form 2848 provided
that “Notices and other written communications will be sent to
the first representative listed in line 2.” Mr. Mark was the
first, and only, representative listed in line 2.
During October 1993, petitioners moved to Wellington,
Nevada. Petitioners did not notify respondent of their new
address prior to August 26, 1994.
On August 26, 1994, respondent sent a notice of deficiency
to petitioners at the Sand Canyon Road address. On that same
date, a copy of the notice of deficiency was sent to Mr. Mark.
In the notice, respondent determined a deficiency in petitioners’
income tax and an accuracy-related penalty for the taxable year
1991 in the amounts of $8,026 and $533.60, respectively.
Petitioners did not receive the notice of deficiency; in
contrast, Mr. Mark received the copy that was sent to him.
On November 3, 1994, Mr. Mark prepared petitioners’ 1993 tax
return using their Wellington, Nevada, address.
After the notice of deficiency was issued, but prior to the
end of the 90-day period in which petitioners could file a
petition with this Court, Mr. Mark contacted respondent’s
Examination Division on several occasions with respect to
respondent’s deficiency determination. Thus, on November 1,
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