Greg William Gouveia, a.k.a. Greg W. Gouveia, a.k.a. Greg Gouveia & Carol Ann Gorveia, a.k.a. Carol Gouveia, et al. - Page 28

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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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