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the liability late through installment payments. Further, Lois
Etkin had specific notice that her tax liability for the taxable
year 2000 would remain unpaid because she signed the joint income
tax return for the taxable year 2000, showing a significant
balance due, while her request for innocent spouse relief was
being considered for the taxable years 1997-99. Accordingly, we
conclude that respondent did not abuse his discretion by acting
arbitrarily, capriciously, or without sound basis in fact in
denying Lois Etkin’s request for equitable relief under section
6015(f).
In reaching all of our holdings herein, we have considered
all arguments made by the parties, and to the extent not mentioned
above, we find them to be irrelevant or without merit.
To reflect the foregoing,
Decisions will be entered
for respondent.
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