Zenobia Elisia Clary Ziegler - Page 14

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          1998 joint return, petitioner’s equitable argument is not enough            
          to overcome evidence that the omitted income was her earned                 
          income and that she knew or had reason to know the income had               
          been omitted from the 1998 joint return.  Petitioner’s equitable            
          argument is also insufficient to overcome a record devoid of any            
          evidence regarding economic hardship.                                       
               On the record before us, we find that petitioner has failed            
          to carry her burden of establishing that respondent abused his              
          discretion in denying her relief under section 6015(f).                     
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          

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