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requested that Mr. Gazi and Ms. Gazi’s estate submit Form 433-A
within 14 days of the date of that letter, i.e., by April 10,
2006. Mr. Gazi and Ms. Gazi’s estate did not submit Form 433-A
by April 10, 2006. On April 18, 2006, at the request of Ms.
Ciraolo, the settlement officer agreed to reschedule the Appeals
Office hearing from April 25 to May 15, 2006. On May 15, 2006,
the day on which the rescheduled Appeals Office hearing was to be
held, Ms. Ciraolo called the settlement officer to inform him
that Mr. Gazi and Ms. Gazi’s estate were still not ready to
submit Form 433-A and to request that the Appeals Office hearing
be rescheduled to at least one week later. The settlement
officer refused to reschedule the Appeals Office hearing, but
advised Ms. Ciraolo that, when Mr. Gazi and Ms. Gazi’s estate
were ready to submit Form 433-A, they could do so with a request
for an installment agreement through respondent’s compliance
division. Mr. Gazi and Ms. Gazi’s estate did not submit Form
433-A and their offer-in-compromise until July 13, 2006, almost
two months after Ms. Ciraolo requested another rescheduling of
the Appeals Office hearing from May 15, 2006, to at least one
week later.
Based upon our examination of the entire record before us,
we find that respondent did not abuse respondent’s discretion in
making the determinations in the notice of determination with
respect to the notice of intent to levy. On that record, we
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Last modified: March 27, 2008