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Ms. Flandez also noted that the arguments petitioner
presented to her raised the possibility of asset transfers in an
attempt to avoid collection.
Petitioner also argues that respondent made blanket “pro
forma” denials of Hoyt investor section 6015 claims. We
disagree. Respondent’s agents assigned to review petitioner’s
claim conducted a full, impartial, and fair evaluation of
petitioner’s section 6015 claim. They reached their conclusions
on the basis of the facts and circumstances present in this case.
See also Doyel v. Commissioner, T.C. Memo. 2004-35, in which we
further explained the flaws in petitioner’s arguments on this
issue.
On the basis of all the facts and circumstances, we conclude
that respondent did not abuse his discretion in denying
petitioner relief pursuant to section 6015(f).
In reaching our holdings, we have considered all arguments
made by the parties, and, to the extent not mentioned above, we
conclude they are irrelevant or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
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