Questione giuridica chiave
Whether the conditions for restoration of the objection deadline were met after service on the designated representative.
Decisione estratta
No. Service on the representative named in the tax return was attributable to the taxpayers; no basis for deadline restoration was shown.
Motivazione estratta
By signing the return and designating A. AG as representative, the taxpayers created a valid representation appearance. The authorities could rely on good faith and were entitled, indeed bound, to serve the assessment on that representative. The complaint’s arguments were merely appellatory and did not establish a breach of federal law.