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for April 9, 2002. The letter referenced the 1985 tax year and
clearly explained that the purpose of the conference was to
accomplish objectives outlined in section 6330; i.e., to address
the issues raised in petitioner’s appeal request and to discuss
collection alternatives. The letter also warned that failure to
appear or to make alternative arrangements would result in
closing of the matter based on information in the case file.
Petitioner declined to meet with Ms. Carter on April 9th,
and his representative sent a letter stating that he would call
Ms. Carter “to reschedule a meeting, if appropriate.” A
conference was eventually scheduled, after delay attempting to
accommodate petitioner, for June 26, 2002. Although it is
apparent that document review precipitated by the FOIA request
was to be a part of the meeting, the record does not support
petitioner’s claim that the conference was entirely separate and
otherwise divorced from petitioner’s broader collection appeal
for 1985. Mr. Lynch explicitly stated in his letter of June 13,
2002, discussing the scheduled appointment: “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.”
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