- 4 - Respondent subsequently initiated an examination of petitioner’s years at issue. On June 13, 2002, respondent received petitioner’s Form 2848, Power of Attorney and Declaration of Representative, for 2000 listing John W. Townshend, an accountant, as the representative to whom petitioner delegated a power of attorney.3 On October 21, 2002, petitioner filed a Form 1040, U.S. Individual Income Tax Return, for 2001, including his Schedule C, which reported gross receipts of $4,196,750 and costs of goods sold and deductions totaling $4,238,057.4 In late 2002, respondent’s Revenue Agent, Dennis Bok, attempted to reach Mr. Townshend by telephone on 12 occasions. With each attempt, Agent Bok left a message stating his name, telephone number, and a brief message. Agent Bok received no response from Mr. Townshend. On January 3, 2003, Agent Bok prepared a memorandum for his superiors requesting a bypass of power of attorney in which he stated that Mr. Townshend, in not communicating with me, is attempting to delay and hindered [sic] my ability to 3 Petitioner offered Forms 2848 for 1999, 2000, and 2001 into evidence which were dated Sep. 20, 2002, Oct. 20, 2001, and Oct. 20, 2001, respectively. However, the record indicates respondent only received a Form 2848 for 2000. The record also indicates that petitioner hired Mr. Townshend after Jan. 31, 2002. Thus, from the record it appears the Forms 2848 for 2000 and 2001 were incorrectly dated. 4 The latter amount comprised returns and allowances of $1,406, costs of goods sold of $3,765,466, and total expenses of $471,185.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007