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for relief relates), respondent points to the fact that peti-
tioner did not timely file petitioner’s 1994 return as an indica-
tion that she did not make a good faith effort to comply with the
tax laws in at least 1 taxable year following the taxable year to
which petitioner’s request for relief related. Park v. Commis-
sioner, 25 F.3d 1289, 1299 (5th Cir. 1994), affg. T.C. Memo.
1993-252. Petitioner gave no explanation as to why she filed
petitioner’s 1994 return more than 1 year past the due date for
filing that return. On the record before us, we find that
petitioner has failed to carry her burden of establishing that
the negative factor set forth in section 4.03(2)(e) of Revenue
Procedure 2000-15 is not present in the instant case.
On the record before us, we find that petitioner has failed
to carry her burden of establishing any other factors that weigh
in favor of granting relief under section 6015(f) and that are
not set forth in sections 4.02(1) and 4.03(1) of Revenue Proce-
dure 2000-15.
Based upon our examination of the entire record before us,
we find that petitioner has failed to carry her burden of showing
that respondent abused respondent’s discretion in denying her
relief under section 6015(f) with respect to the unpaid 1993
liability.
We have considered all of petitioner’s arguments and conten-
tions which are not discussed herein, and we find them to be
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