Ingrid Capehart - Page 49

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          Bartak v. Commissioner, supra; Ellison v. Commissioner, supra;              
          Doyel v. Commissioner, supra.                                               
               4.  Conclusion                                                         
               After examining the entire record before us, we conclude               
          that petitioner has failed to carry her burden of proving that              
          respondent abused his discretion in denying petitioner relief               
          from joint and several liability under section 6015(f) for each             
          of the years at issue.16                                                    
               To reflect the foregoing,                                              

                                                  An appropriate decision             
                                             will be entered.                         


















               16We 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.                                      

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