MEMORANDUM OPINION
HOLMES, Judge:
In September 1998, petitioner Thomas Hunter moved from Gallatin to Hendersonville, Tennessee. He knew when he moved that the IRS was auditing his tax returns. In October 1998, he hired new accountants to represent him, and filed a power-of-attorney form that both directed the IRS to send copies of all correspondence to their office in Nashville and listed his own new address in Hendersonville. In January 1999, respondent...
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