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record contains evidence of repeated instances where petitioner
or his representatives delayed or postponed appointments, failed
to provide timely substantive responses to requests for
information, or otherwise declined to act with any alacrity upon
attempted communications from respondent.
Additionally, the processing of petitioner’s 1997 through
1999 tax years was likely impacted by certain other
administrative and judicial actions instituted by petitioner.
Petitioner is no stranger to the Federal forum when it comes to
his tax matters. Documents submitted in this case and public
records reflect that petitioner has apparently been involved in
at least three actions against the Internal Revenue Service based
on the Freedom of Information Act (FOIA), 5 U.S.C. sec. 552
(2000). Megibow v. Commissioner, No. 03 CV 6020 (S.D.N.Y. Dec.
22, 2003); Megibow v. Commissioner, No. 01 CV 2979 (S.D.N.Y. Jan.
14, 2002); Megibow v. Commissioner, No. 97 CV 9500 (S.D.N.Y. Nov.
30, 1998). At least two FOIA requests, one of which seems to
have precipitated the second of the just-listed suits, were made
during the examinations of petitioner’s 1997 through 1999 returns
and pertained to those audits. A third FOIA request related to
matters is this case was submitted after the issuance of the
notice of deficiency and appears to have led to the most recent
of the FOIA suits enumerated above.
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