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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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Last modified: May 25, 2011