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We need not resolve the foregoing dispute between the parties.
That is because, based upon our examination of the entire record
in this case, including petitioner’s additional information that
is part of the record established at trial, we find that peti-
tioner 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 taxable year 1995.22
We initially address certain of the arguments that peti-
tioner advances on brief, all of which we find to be without
merit. To illustrate, petitioner argues on brief that
a ruling in favor of the spouse [petitioner] does not
mean the tax debt is forgiven or that it will never be
paid. It only means that based upon the present facts
and circumstances, it is not equitable to compel the
requesting spouse [petitioner] to pay the tax debt in
full at this time. * * * If an economic hardship is
present, then Congress has declared that the present
collection of the tax is to be suspended as to the
21(...continued)
mining whether respondent abused respondent’s discretion in
denying that relief, we would give whatever weight we consider
appropriate to the evidence to which respondent objected.
22In so holding, we have considered petitioner’s contention
that respondent did not fulfill what petitioner claims was
respondent’s responsibility to investigate and ascertain during
the administrative consideration of petitioner’s request for
relief under sec. 6015(f) all of the facts and circumstances with
respect to petitioner’s claim for equitable relief under sec.
6015(f). Regardless of whether or not petitioner’s contention
has any merit, petitioner had the opportunity at trial to intro-
duce admissible evidence into the record that established all of
the facts which she claims respondent had a duty to investigate
and ascertain and on which she relies in order to show that
respondent abused respondent’s discretion in denying her relief
under sec. 6015(f).
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