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On February 18, 2005, Linda Olson (Olson), a certified
public accountant to whom the Bedrosians delegated a power of
attorney, sent Revenue Agent Deborah Smyth a letter informing
Agent Smyth of a change of address for SCP, JCB, and Investors.
Olson’s letter listed 270 North Canon Drive #1209, Beverly
Hills, California 90210 (North Canon), a private mailbox, as the
new address. Olson did not have power of attorney for any of
the entities, only for the Bedrosians as individuals.
On April 5, 2005, 3 days before the mailing of the 14
FPAAs, Olson notified Revenue Agent Smyth by telephone that the
Bedrosians’ mail could no longer be delivered to the North Canon
address and that 2934½ Beverly Glen Circle, #419, Los Angeles,
California 90077 (Beverly Glen) was the new private mailbox
being used by the Bedrosians. Olson notified Revenue Agent
Smyth that the Bedrosians’ residence was still Rocco. As a
result of the telephone conversation, Revenue Agent Smyth
prepared Forms 2363, Master File Entity Change, for SCP,
Investors, and the Bedrosians listing the Beverly Glen address.
On April 8, 2005, respondent mailed 14 FPAAs regarding SCP
to addressees at three different addresses: (1) Stone Canyon,
(2) Beverly Glen, and (3) North Canon. Petitioner did not file
a petition to contest the FPAA until May 1, 2007, more than 2
years after the FPAAs had been sent. No petition to contest the
FPAAs had previously been filed by any partner. The FPAAs were
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