Caution:

If shared, do not further modify the workpaper. If later modified, share the workpaper again.

11. Agent’s notes concerning records the organization failed to produce.

Write to the taxpayer, reminding the taxpayer of what had been said, and note the failure to produce the documents. The letter with the taxpayer's verbal representations and failures to produce is then part of the record. Of course, any written response from the taxpayer is also a part of the record.