E. Carolyn Mellen - Page 42




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            respect to the year at issue that are not set forth in Revenue                              
            Procedure 2000-15 and that weigh in favor of granting her relief                            
            under section 6015(f).                                                                      
                  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 taxable year                               
            1995.                                                                                       
                  We have considered all of the contentions and arguments of                            
            the parties that are not discussed herein, and we find them to be                           
            without merit, irrelevant, and/or moot.                                                     
                  To reflect the foregoing,                                                             
                                                             Decision will be entered                   
                                                       for respondent.                                  
























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