- 28 - 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 aPage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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