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to handle petitioner’s income tax matters for 1998 and 1999.
Petitioner was aware that Lorant hired Mr. Penn on petitioner’s
behalf, and petitioner approved the hiring of Mr. Penn. On April
22, 2002, Lorant executed on behalf of petitioner a Form 2848
appointing Mr. Penn as petitioner’s representative for the
taxable years 1997 through 2003. Lorant signed the Form 2848 as
“Lorant Szasz, P.O.A. for Roland Szasz”. Mr. Penn signed the
Form 2848 on the same day.
From about April 2002 through May 2003, Mr. Penn
corresponded with respondent’s agent on approximately 40
occasions. As a matter of practice, Mr. Penn would then
correspond with Lorant, who would relay all the information to
petitioner. When Mr. Penn was unable to persuade respondent to
accept petitioner’s returns as filed, he executed on October 15,
2002, a Form 872 consenting to extend the period of limitations
for 1998 and 1999 to June 30, 2003 (last consent). Mr. Penn
signed the last consent as petitioner’s representative.
Respondent’s authorized official countersigned it on October 21,
2002.
F. Notice of Deficiency
On May 14, 2003, respondent issued to petitioner a notice of
deficiency for 1998 and 1999. Respondent determined that
petitioner is not entitled to claim his parents as dependents,
that petitioner is not entitled to head-of-household filing
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