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claims, the Appeals officer denied petitioners’ offer of an
installment agreement and determined that: (1) Pursuant to their
proposed installment agreement, only $48,000 would have been paid
towards their total outstanding liability of $55,362.13; (2)
petitioners were delinquent in paying their joint income tax
liability for the taxable year 2000 and had not made any
estimated tax payments for the taxable year 2001; and (3) the
revenue agent was correct in his determination that petitioners’
proposed installment agreement was unacceptable because they
could afford to pay $4,912 per month in the first year and $7,106
per month in the years thereafter.
In addition, in a Form 866-A, Explanation of Items, the
Appeals Office denied petitioner Lois Etkin’s claim for equitable
relief under section 6015(f) for the taxable years 1997-99. In
analyzing Lois Etkin’s entitlement to equitable relief under
section 6015(f), the Appeals officer relied on the following
factors: (1) Lois Etkin was married to and still residing with
Davis Etkin; (2) Davis Etkin did not abuse Lois Etkin; (3) Lois
Etkin failed to establish that she would suffer economic hardship
if relief was not granted; (4) Lois Etkin derived a significant
benefit from not paying the tax liabilities; (5) some of the tax
due in each year at issue was attributable to Lois Etkin’s
income; (6) there were perceptible asset transfers between
petitioners; and (7) Lois Etkin was well educated and knew or had
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Last modified: May 25, 2011