- 41 -
On the record before us, we find that Ms. Collier has failed
to carry her burden of establishing any other factors with
respect to any of the years at issue 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 Procedure 2000-15.
Based upon our examination of the entire record before us,
we find that Ms. Collier 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
assessment for each of the years at issue.
We have considered all of the contentions and arguments of
Ms. Collier that are not discussed herein, and we find them to be
without merit and/or irrelevant.
To reflect the foregoing and the concession of Ms. Collier
as to taxable year 1987,
Decision will be entered
for respondent.
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