N.Y. Comp. Codes R. & Regs. tit. 20, § 2394.9
(a) The State Tax Commissionshall issue a decision within 15 business days from the latter ofthe;
(d) The State Tax Commissionin rendering its decision with respect to the issue of whether theissuance of the warrant commanding a levy upon the real and personalproperty of any person is reasonable under the circumstances, shallmake findings of fact and conclusions of law as to whether:
(1) taxes, penaltiesor interest are claimed to be due and owing the department from suchperson;
(2)