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stack of records concerning Mr. Newstat and his federal tax
liabilities” would be available at the meeting for his review.
However, by letter dated June 11, 2002, Mr. Lynch asked that
Ms. Carter contact him to reschedule the planned meeting. The
basis for this request was that petitioner wished to be present
when the records were reviewed but would be unable to attend the
June 13, 2002, conference because of health problems. Mr. Lynch
also enclosed with the letter a new Form 2848 authorizing his
representation of petitioner for “All tax periods 1980 through
2001, inclusive” on grounds that “there may be issues for years
other than those set forth on my previously submitted power of
attorney”.
Per Mr. Lynch’s request, the meeting was rescheduled for
June 26, 2002. A letter from Mr. Lynch to Ms. Carter dated June
13, 2002, confirmed this date and communicated the following:
Both Mr. Newstat and I will attend to review his file.
I will provide Mr. Newstat with forms 433-A and 433-B.
I need to first confirm there are outstanding tax
liabilities. I understand if Mr. Newstat does not
submit the financial disclosure forms during our
meeting, you will permit Mr. Newstat to review and copy
portions of his file but will likely close the appeal
file concerning this matter and the Service will resume
collection activity.
Mr. Lynch provided petitioner with a copy of this letter.
On June 26, 2002, Mr. Lynch, but not petitioner, attended
the scheduled meeting with Ms. Carter. At the meeting, Mr. Lynch
reviewed the files made available to confirm petitioner’s
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