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reason to know that the tax liabilities would not be paid and
were not solely attributable to Davis Etkin. Further,
petitioners did not offer any evidence to rebut the Appeals
officer’s determination.
B. The Taxable Year 2000 Hearing
1. Notice of Federal Tax Lien
On April 5, 2002, respondent filed a notice of Federal tax
lien in the County of Schenectady, New York, for the taxable year
2000. On April 11, 2002, respondent issued to petitioners the
notice of Federal tax lien filing and a Form 1058. On May 3,
2002, petitioners timely submitted a Form 12153 requesting a
hearing under section 6320. On their Form 12153, petitioners
claimed (as they had in the Form 12153 for the 1997-99 tax years)
that respondent requested monthly payments that greatly exceeded
their ability to pay and requested an installment agreement.
Along with petitioners’ Form 12153, Lois Etkin submitted a Form
8857, requesting innocent spouse relief, claiming that she
believed her withholding was sufficient to pay her income taxes,
and that her husband had assumed responsibility for the filing of
their income tax return and payment of their joint tax liability
for the taxable year 2000. Although petitioners incurred an
additional income tax liability for the taxable year 2000 of
$17,759.51, petitioners made payments towards their outstanding
joint income tax liabilities for the taxable years 1997 and 2000,
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