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years 1997-99. In addition, petitioners’ proposal did not qualify
for the 5-year rule because they failed to provide substantiation
for the “conditional” and “excessive necessary” expenses listed on
their financial statement. See Schulman v. Commissioner, T.C.
Memo. 2002-129 (citing 2 Administration, Internal Revenue Manual
(CCH), sec. 5.15.1.3(8)(a), at 17,655). Respondent was therefore
within his discretion to reject petitioners’ proposed installment
agreement.
II. Respondent Did Not Abuse His Discretion When He Denied
Equitable Relief Pursuant to Section 6015(f) to Lois Etkin
for the Taxable Years 1997, 1998, 1999, and 2000
We note this case involves unpaid tax liabilities for the
years in issue. Because no understatements of tax or deficiencies
are involved, Lois Etkin does not qualify for relief under section
6015(b) or (c). See sec. 6015(b)(1) and (c)(1); Washington v.
Commissioner, 120 T.C. 137, 146-147 (2003). Therefore, our review
is limited to section 6015(f), which permits in certain
circumstances relief from joint and several liability for unpaid
taxes. See Ewing v. Commissioner, 118 T.C. 494, 497 (2002).
Section 6015(f) grants the Commissioner discretion to grant
equitable relief from tax liability to a spouse if, taking into
account all the facts and circumstances, it is inequitable to hold
the spouse liable for any unpaid tax or any deficiency (or any
portion of either) and relief is not available under section
6015(b) or (c). In order to prevail, Lois Etkin must demonstrate
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