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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.
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Last modified: November 10, 2007