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which reduced their total outstanding income tax liability from
$55,362.13 on March 21, 2002, to $45,776.13 on September 16,
2003.
The factors petitioner Lois Etkin set forth for entitlement
to section 6015(f) equitable relief for the taxable year 2000 are
virtually identical to the factors set forth in her claim for
equitable relief associated with the taxable years 1997-99.
2. Hearing
During a phone call to the Appeals officer on August 13,
2003, petitioners proposed an installment agreement to satisfy
their outstanding joint liabilities for the taxable years 1997
through 2000. The proposed agreement provided that petitioners
would pay $762.94 per month, which would have fully satisfied
their outstanding income tax liability of $45,776.13 within 5
years. On July 21, 2003, the Appeals Office issued a letter to
petitioners informing them that Lois Etkin was not entitled to
equitable relief under section 6015(f) and inviting petitioners
to raise any additional issues regarding their hearing.
Petitioners did not have legal representation during the hearing
for the taxable year 2000. After a phone call with the Appeals
officer in response to the Appeals Office’s July 21, 2003,
letter, petitioners agreed to raise any additional issues by mail
within 10 days, but failed to do so. The Appeals officer
followed the administrative procedures which require requesting a
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Last modified: May 25, 2011