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agreement would not be considered because of petitioners’ poor
compliance record. Respondent issued the notice of determination
on April 8, 2003, sustaining the levy.
In the petition, petitioners alleged errors in the notice of
determination, specifically that Appeals failed to give them a
fair hearing and that Appeals failed to act properly with regard
to the collection activity. After the petition was filed,
counsel for respondent requested that Appeals discuss collection
alternatives with petitioners at a face-to-face hearing.
Petitioner3 and respondent’s SO met on September 9, 2003, and
discussed collection alternatives. Petitioners submitted an OIC
on November 6, 2003. On December 1, 2003, the SO sent
petitioners a letter requesting that they complete missing items
on the form and submit additional information.
This case was calendared for trial at the May 3, 2004,
session of this Court in New York, New York. Petitioners filed a
motion for continuance in which they stated that they would be
submitting an OIC. The Court granted the motion. The case was
then calendared for trial at the session of this Court beginning
on January 24, 2005. Petitioners filed another motion for
continuance in order to retain counsel. The Court granted the
motion and ordered petitioners to submit an OIC to respondent no
later than March 1, 2005. Petitioners filed a status report on
3 References to petitioner are to William J. DiCindio.
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