Thomas W. Hunter, Jr. - Page 1

                                 T.C. Memo. 2004-81                                   

                               UNITED STATES TAX COURT                                

                        THOMAS W. HUNTER, JR., Petitioner v.                          
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 9856-02.              Filed March 23, 2004.                 

               James David Leckrone, for petitioner.                                  
               Rebecca Dance Harris, for respondent.                                  

                                 MEMORANDUM OPINION                                   

               HOLMES, Judge:  In September 1998, petitioner Thomas Hunter            
          moved from Gallatin to Hendersonville, Tennessee.  He knew when             
          he moved that the IRS was auditing his tax returns.  In October             
          1998, he hired new accountants to represent him, and filed a                
          power-of-attorney form that both directed the IRS to send copies            
          of all correspondence to their office in Nashville and listed his           

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