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In a subsequent letter to Ms. Carter dated April 22, 2002,
Mr. Lynch made a request under the Freedom of Information Act
(FOIA) and section 6103 for all records pertaining to the
determination of petitioner’s 1985, but not 1999, liability.
Mr. Lynch asked that the administrative file first be made
available at the IRS office in Cherry Hill, New Jersey, in order
to determine which documents should be copied, and that
collection action “remain suspended pending production of the
requested documents and our meeting.” Mr. Lynch also enclosed
with the letter a Form 2848, Power of Attorney and Declaration of
Representative, authorizing his representation of petitioner
regarding income taxes from Form 1040 for the years 1985, 1999,
and 2000.5
Thereafter, by a letter dated April 24, 2002, Mr. Lynch
confirmed a telephone conversation with Ms. Carter of that date
during which he “agreed to withdrawal [sic] my document request
as a Freedom of Information Act and Internal Revenue Code � 6103
Request, provided my request can be reinstituted without
prejudice as a FOIA request upon my subsequent written notice to
you.” A further letter of May 30, 2002, from Mr. Lynch to Ms.
Carter confirmed a meeting scheduled for June 13, 2002, as well
as Mr. Lynch’s understanding that “a six or seven inches high
5 The power of attorney authorized representation with
respect to employment taxes for certain quarterly periods in
1982, 1983, and 1986, as well.
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