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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 Court
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