Davis and Lois Etkin - Page 33

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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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