- 4 - 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 werePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: March 27, 2008