- 6 -
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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