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2. Notice of Federal Tax Lien
On October 4, 2000, respondent issued a notice of Federal
tax lien, as required by section 6320(a), for petitioners’ 1997-
99 tax years. On October 12, 2000, petitioners timely submitted
Form 12153 requesting a hearing under section 6320 for taxable
years 1997-99.
3. Lois Etkin’s Request for Innocent Spouse Relief
On December 14, 2000, respondent received from Lois Etkin
Form 8857, Request for Innocent Spouse Relief, for her taxable
years 1997-99. On her Form 8857, Lois Etkin claimed that it
would be inequitable to hold her liable for petitioners’ joint
income taxes because (1) she relied on Davis Etkin to prepare the
income tax returns and pay the taxes, and (2) she believed that
her withholding was sufficient to pay her income taxes for the
aforementioned taxable years. In addition, Lois Etkin submitted
to respondent a completed Questionnaire for Requesting Spouse
during the course of the hearing for the taxable years 1997-99.
4. The Appeals Officer’s Consideration of Petitioners’
Proposed Installment Agreements During Their
Hearing for the Taxable Years 1997-99
In January 2000, before any notices of liens or proposed
levies were issued, petitioners proposed to the revenue agent
handling their case an installment agreement to satisfy their
joint income tax liabilities for the taxable years 1997-99. The
installment agreement required payments of $800 a month over 5
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Last modified: May 25, 2011