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raised was not relevant for inclusion in a collection due process
hearing. Ohrtman further stated that he would maintain
jurisdiction over the case but that he had arranged for another
Appeals officer to conduct a hearing on the interest abatement
issue. He suggested that proof of the items stated in the claim
should be made available when the Appeals officer made contact.
On August 1, 2001, an Appeals officer called to speak to
John R. Serpico. Ehrlich stated that John R. Serpico had passed
away. Ehrlich requested that the Appeals officer refrain from
working on petitioner’s case until the law firm could determine
which of the representatives would handle petitioner’s case. As
a result of the destruction of the World Trade Center on
September 11, 2001, both the administrative and legal files
regarding the Manhattan Associates case were destroyed.
On October 25, 2001, the Appeals officer called Ehrlich
because he had not yet been contacted by a member of Ehrlich’s
firm. Ehrlich informed the Appeals officer that the firm still
had not decided who would handle petitioner’s case. The Appeals
officer informed Ehrlich that, if the firm did not call him back,
he would make a determination on petitioner’s case based on the
information in the file. Ehrlich did not call the Appeals
officer. The Appeals officer reviewed petitioner’s case file,
including the transcripts of petitioner’s tax accounts.
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