Susan L. Abelein - Page 45

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               After considering all of the facts and circumstances, we               
          find that respondent did not abuse his discretion in denying                
          petitioner equitable relief from joint and several liability                
          under section 6015(f).                                                      
          C. Conclusion                                                               
               We have carefully considered all remaining arguments made by           
          the parties for results contrary to those expressed herein and,             
          to the extent not discussed above, find those arguments to be               
          irrelevant, moot, or without merit.                                         
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          

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