Thomas R. Hochschild, Sr. - Page 5




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          FOIA had not been acted upon because more information was                   
          necessary to process the request; i.e., petitioner had not agreed           
          to pay for the cost of copies.  Along with the offer of a                   
          conference by telephone, Ms. Ratzman enclosed a copy of the                 
          statutory notice concerning the 1989, 1990, and 1991 liabilities.           
          Ms. Ratzman also warned petitioner that if “[he did not] * * *              
          contact me by September 8, 2000, I will assume you no longer wish           
          to pursue this matter with Appeals.  Your case will be closed and           
          a notice of determination issued.”                                          
               Petitioner took no action, and, on September 28, 2000,                 
          respondent mailed petitioner a Notice of Determination Concerning           
          Collection Action(s) Under Section 6320 and/or 6330 (the lien or            
          levy determination), notifying petitioner of the determination to           
          proceed with collection of the 1989, 1990, and 1991 income tax              
          liabilities.  On October 4, 2000, petitioner timely petitioned              
          this Court for review of respondent’s determination under section           
          6330(d)(1).                                                                 
               Petitioner’s case was scheduled for trial at the February              
          11, 2002, Columbus, Ohio, trial session.  Immediately before the            
          10:00 a.m. calendar call, petitioner became agitated, which                 
          precipitated a conference in chambers with petitioner,                      
          respondent’s counsel, and the trial Judge.  During the chambers             
          conference, petitioner became highly agitated, and he stated that           
          he was unable to participate in a trial.  Accordingly, the Court            






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