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petitioner’s failure to pay the assessed liabilities, respondent
issued a Collection Due Process Notice and a Notice of Intent to
Levy and Notice of Your Right to Hearing related to petitioner’s
1989, 1990, and 1991 tax years. On December 28, 1999, petitioner
submitted a timely request for a section 6330 hearing.
In a letter that was dated November 16, 1999, and received
by respondent on December 17, 1999, petitioner formally requested
information pertaining to respondent’s determination under the
Freedom of Information Act (FOIA). Petitioner’s request was
denied due to his refusal or failure to agree to pay for copy
costs.
In a July 20, 2000, letter, Appeals Officer Carolyn Ratzman
proposed an August 22, 2000, conference with petitioner and
invited him to reschedule if that date was inconvenient.
Petitioner, in a July 26, 2000, letter, informed Ms. Ratzman that
he had not requested a conference and explained that he would not
be able to attend a conference due to his disability. Petitioner
further explained that he was attempting to obtain information
under the FOIA concerning respondent’s determination of his
liabilities.
In an August 25, 2000, letter, responding to petitioner’s
July 26, 2000, letter, Ms. Ratzman offered petitioner a
conference by telephone. In that same letter, Ms. Ratzman also
informed petitioner that his request for information under the
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Last modified: May 25, 2011