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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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