Gloria Pomerantz - Page 2

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                                     Background                                       
               Gloria Pomerantz (petitioner) is an attorney.  Petitioner              
          timely filed Forms 1040, U.S. Individual Income Tax Return, for             
          1995 and 1996. Respondent subsequently initiated an examination             
          of petitioner’s returns for those years.                                    
               On November 3, 2003, petitioner executed and submitted to              
          respondent a Form 2848, Power of Attorney and Declaration of                
          Representative, appointing Allan Serchay (Mr. Serchay),                     
          identified as a certified public accountant, to act as her                  
          representative with regard to Federal income tax matters for 1995           
          through 1998.  Paragraph 5 of the Form 2848 states:                         
               Acts authorized.  The representatives are authorized to                
               receive and inspect confidential tax information and to                
               perform any and all acts that I (we) can perform with                  
               respect to the tax matters described on line 3, for example,           
               the authority to sign any agreements, consents, or other               
               documents.  The authority does not include the power to                
               receive refund checks (see line 6 below), the power to                 
               substitute another representative, the authority to execute            
               a request for a tax return, or a consent to disclose tax               
               information unless specifically added below, or the power to           
               sign certain returns.                                                  
          The remainder of paragraph 5 of the Form 2848, which allows a               
          taxpayer to list specific additions or deletions to the acts that           
          the representative is authorized to perform, is blank.                      
               On January 30, 2004, Mr. Serchay executed, on petitioner’s             
          behalf, a Form 4549, Income Tax Examination Changes, consenting             
          to the immediate assessment and collection of increased taxes,              
          interest, and fraud penalties for petitioner’s taxable years 1995           






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