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upholding a lien for petitioners’ taxable year 2000.
The issues for decision are:
(1) Did respondent abuse his discretion in upholding the
liens under section 6320 in the notices of determination for
petitioners’ taxable years 1997, 1998, 1999, and 2000? We hold
that respondent did not abuse his discretion.
(2) Did respondent abuse his discretion in upholding the
proposed levy under section 6330 in the notice of determination
for petitioners’ taxable year 1999? We hold that respondent did
not abuse his discretion.
(3) Did respondent abuse his discretion in denying
petitioner Lois Etkin equitable relief under section 6015(f) for
the taxable years 1997, 1998, 1999, and 2000? We hold that
respondent did not abuse his discretion.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioners Davis Etkin
and Lois Etkin have been married and resided together at all
times in Schenectady, New York, since 1990. Davis Etkin is the
former president of Off-Track Betting Organization. Lois Etkin
is a retired school teacher with a master’s degree in education.
Petitioners filed joint income tax returns for 1997, 1998, 1999,
and 2000. They reported tax liabilities due, but these
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