- 5 - 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 CourtPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011