-5-
making several Freedom of Information requests due, in part, to
the documents enclosed with the May 18, 2000, letter. This
letter also stated that petitioners had contacted someone to
represent them at the hearing but that this person had not as of
yet agreed to represent them and had informed them that he could
not represent them until after July 15, 2000.
Appeals never responded to Mr. Bartschi’s June 3, 2000,
letter, or held a face-to-face hearing with either petitioner.
Instead, on the basis of the above-mentioned letters and attached
documents, Appeals issued to petitioners on July 13, 2000, a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 for 1993, 1995, and 1997. This notice
reflected the determination of Appeals to sustain the proposed
levy and advised petitioners that this Court is the proper forum
in which to file a petition should petitioners decide to seek
judicial review of the determination.
On August 11, 2000, petitioners filed a Complaint with the
United States District Court for the District of Arizona. The
Court dismissed that Complaint on September 5, 2001, for lack of
subject matter jurisdiction. Bartschi v. Tracy, 88 AFTR 2d
2001-6223, 2001-2 USTC par. 50,672 (D. Ariz. 2001).
Discussion
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