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Etkin’s claim for equitable relief under section 6015(f) for each
of the taxable years at issue, including 1997 and 1998. Section
6320(c) incorporates section 6330(c), (d), and (e) by reference
(with the exception of section 6330(d)(2)(B)). Section
6330(c)(2)(A) gives the taxpayer the right to raise any relevant
spousal defenses in connection with the hearing. Section 6330(d)
is the specific provision that governs our jurisdiction to review
a proposed collection action. Therefore, this Court has
jurisdiction over petitioners’ sections 6320 and 6015(f) claims
for each of the taxable years at issue.3
I. Respondent Did Not Abuse His Discretion Rejecting
Petitioners’ Proposed Installment Agreements, and Upholding
the Proposed Actions to Collect Petitioners’ Joint Income Tax
Liabilities for the Taxable Years 1997, 1998, 1999, and 2000
A. Background on Proposed Installment Agreements
Section 6159 authorizes the Commissioner to enter into
installment agreements with taxpayers to satisfy their tax
liabilities if the Commissioner determines that such agreements
will facilitate the collection of the liability. The IRM,
together with sections 301.6159-1, 301.6320-1, and 301.6330-1,
Proced. & Admin. Regs., establishes the IRS procedures for
3Lois Etkin received a notice of determination in response
to her request for relief under sec. 6015 and was notified that
she could petition a stand-alone sec. 6015 case under sec.
6015(e). See sec. 301.6330-1(i)(2), Q&A-15, Proced. & Admin.
Regs. Lois Etkin did not file such a petition. Nevertheless, we
have jurisdiction over the sec. 6015(f) claims for each taxable
year at issue pursuant to sec. 6320(c).
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