Davis and Lois Etkin - Page 9

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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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