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statement from which the Appeals officer could determine
petitioners’ income and allowable expenses, and (2) they failed
to provide substantiation for their expenses as required by the
IRM.
As to Lois Etkin’s claim for equitable relief under section
6015(f), respondent considered the following factors dispositive
of the issue: (1) Lois Etkin signed a joint income tax return
with her husband for the taxable year 2000, while the hearing was
taking place for the taxable years 1997-99; and (2) she was well
educated. On the basis of these two factors, respondent
determined that Lois Etkin had reason to know when she signed the
2000 income tax return that the tax liability would not be paid.
As a result of this determination and Lois Etkin’s failure to
meet some of the requirements set forth in Rev. Proc. 2000-15,
sec. 4.02, 2000-1 C.B. 447, 448, respondent denied Lois Etkin’s
claim for relief under section 6015(f).
OPINION
Sections 6320 and 6330 provide for Tax Court review of the
Commissioner’s administrative determinations to proceed with
liens and levies. Where the validity of the underlying tax
liability is at issue, the Court will review the matter de novo.
Davis v. Commissioner, 115 T.C. 35, 39 (2000). However,
petitioners have not challenged the validity of the underlying
tax liability. Because the underlying tax liability and section
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