Roland Gyula Szasz - Page 9

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          (first consent).  Lorant signed the first consent as “Lorant                
          Szasz, P.O. for Roland Szasz”.  Respondent received the first               
          consent on July 19, 2001, and respondent’s authorized official              
          countersigned it on July 23, 2001.                                          
               On August 3, 2001, Lorant executed on behalf of petitioner             
          another Form 872 consenting to extend the period of limitation              
          for 1998 to December 31, 2002 (second consent).  Lorant signed              
          the second consent as “Lorant Szasz, P.A. for Roland Szasz”.                
          Respondent received the second consent on August 9, 2001, and               
          respondent’s authorized official countersigned it on that same              
          day.                                                                        
               On December 24, 2001, Lorant executed on behalf of                     
          petitioner another Form 872 consenting to extend the period of              
          limitation for 1998 to December 31, 2002 (third consent).6                  
          Lorant signed the third consent as “Lorant Szasz, P.O.A. for                
          Roland Szasz”.  Respondent’s authorized official countersigned it           
          on December 28, 2001.                                                       
               For reasons not fully explained in the record, Lorant became           
          unable to continue to represent petitioner in the audit.                    
          Consequently, in or about April 2002, Lorant hired on behalf of             
          petitioner a certified public accountant, Scott Penn (Mr. Penn),            


               6  There is no explanation in the record why Lorant executed           
          two separate Forms 872, Consent to Extent the Time to Assess Tax,           
          consenting to extend the period of limitations to the same date             
          of Dec. 31, 2002.                                                           





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