Verna Doyel - Page 38

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          procedures, and a uniform denial letter, in the Hoyt investor               
          section 6015 cases; however, respondent did not make blanket                
          denials of Hoyt investor section 6015 relief claims.  We find               
          nothing abusive in using this form letter.                                  
               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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