Charles Deverna - Page 10

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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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