- 15 - outweighed by the significant benefit petitioner received from the underpayment, her knowledge or reason to know that the reported liability would be unpaid, and her failure to demonstrate economic hardship. Based on the above, we find that petitioner has failed to carry her burden of showing respondent abused his discretion in denying her equitable relief under section 6015(f). In reaching our holding herein, we have considered all arguments made, and, to the extent not mentioned above, we conclude that they are moot, irrelevant, or without merit. To reflect the foregoing and respondent’s concession regarding petitioner’s 1997 tax year, An appropriate decision will be entered.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15Last modified: November 10, 2007