Robert Newstat - Page 6

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          In closing, the letter stated:                                              
               I have enclosed Form 433-A for Mr. Newstat to complete                 
               so that I may evaluate collection alternatives.  Please                
               return completed Form 433-A to me by February 25, 2002.                
               In addition, please call me by February 25, 2002 at the                
               telephone number shown above to discuss any questions                  
               you may have regarding the computation of the                          
               collection statute expiration dates and collection                     
               alternatives.                                                          
          Petitioner received a copy of the foregoing letter in mid-March             
          of 2002.                                                                    
               At some point after receipt of the February 5, 2002, letter,           
          Mr. Fendrick advised Ms. Carter by a voice mail message4 that he            
          no longer represented petitioner, that petitioner was in the                
          process of retaining a new attorney, and that he expected that              
          Ms. Carter would be hearing from the new counsel within 2 weeks.            
          Ms. Carter responded with a letter dated March 28, 2002, sent               
          directly to petitioner and explaining that “Approximately one               
          month has passed since Mr. Fendrick informed me of this change              
          [of representatives], and no one has contacted me on your behalf            
          regarding this matter.”  In the letter, the heading of which                
          referenced the 1985 income tax, Ms. Carter scheduled an in-person           
          appointment for April 9, 2002, and advised petitioner that if he            
          did not appear for the meeting or call beforehand to cancel, she            

               4 An attachment to the Notice of Determination Concerning              
          Collection Action(s) Under Section 6320 and/or 6330 gives Mar.              
          26, 2002, as the date this message was left.  That date, however,           
          is difficult to reconcile with the letter sent by Ms. Carter in             
          response, described infra in text.                                          





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