Pamela J. Ellison - Page 27

                                       - 27 -                                         
          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 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.                          

Page:  Previous  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27