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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