- 9 - 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 hadPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011