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liabilities and asked Ms. Carter to photocopy and provide
selected documents from those files. Mr. Lynch concurred with
Ms. Carter that he would submit petitioner’s Form 433-A,
Collection Information Statement for Wage Earners and Self-
Employed Individuals, within 2 weeks so that collection
alternatives could be considered. Approximately 2 months later,6
Mr. Lynch advised Ms. Carter by letter dated August 28, 2002,
that petitioner had been hospitalized several times over the
summer but that a meeting had been scheduled with petitioner for
September 3, 2002, to complete the Form 433-A.
Thereafter, a letter dated September 27, 2002, and
referencing in the heading both the 1985 and 1999 tax periods,7
was sent by Ms. Carter to Mr. Lynch. The letter stated:
Enclosed you will find the documents you requested
during our conference with respect to the above
referenced matter. According to your letter dated
August 28, 2002, you were to call me after you met with
Mr. Newstat to finalized [sic] Form 433-A on September
3, 2002. I have not heard from you to date nor have I
received Form 433-A as requested. Therefore, a
determination has been made to uphold the collection
action proposed with respect to the above periods.
You and Mr. Newstat will be receiving the determination
letters issued discussing the basis for my findings.
6 The stipulation of facts filed by the parties incorrectly
refers to the Aug. 28, 2002, letter as being sent approximately 1
month after the June 26, 2002, meeting.
7 The heading likewise listed the various period in 1982,
1983, and 1986 germane to the trust fund recovery penalties.
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