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between Mr. Izen and either trust, or between Mr. Izen and the
trustees.
By filing Form 2848, the taxpayer authorizes the
representative to represent the taxpayer before the IRS and to
perform any act that the taxpayer can perform, subject to certain
exceptions not relevant here. While the filing of Form 2848 is a
factor we consider in deciding whether the petition was filed
with the actual or apparent authority of the taxpayer, it is not
determinative; we also consider all of the facts and
circumstances in our analysis of the existence and scope of an
agency relationship. See John Arnold Executrak Sys., Inc. v.
Commissioner, supra; Shopsin v. Commissioner, T.C. Memo. 1984-
151, affd. without published opinion 751 F.2d 371 (2d Cir. 1984).
In Trans World Travel v. Commissioner, supra, John Arnold
Executrak Sys., Inc. v. Commissioner, supra, and Shopsin v.
Commissioner, supra, we held that the taxpayer’s accountant or
attorney had acted as the taxpayer’s authorized agent in filing
and signing the petition filed with this Court on facts showing
that, in addition to executing Form 2848 and appointing the
accountant or attorney as its representative, the taxpayer
routinely delegated the handling of all tax matters to the agent;
spoke regularly with the agent in regard to tax matters; relied
on the agent for advice and deferred to the agent’s judgment on a
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