- 68 -
found that the legal obligation positive factor set forth in
section 4.03(1)(e) of Revenue Procedure 2000-15 is a neutral
factor in this case. On the record before us, we find that the
legal obligation negative factor set forth in section 4.03(2)(f)
of that revenue procedure is a neutral factor in this case.
On the record before us, we find that petitioner has failed
to carry her burden of establishing any other factors with respect
to the taxable years at issue that are not set forth in Revenue
Procedure 2000-15 and that weigh in favor of granting her relief
under section 6015(f).
Based upon our examination of the entire record before us, we
find that petitioner has failed to carry her burden of establish-
ing that respondent abused respondent’s discretion in denying her
relief under section 6015(f) with respect to any of the taxable
years at issue.
We have considered all of the contentions and arguments of
the parties that are not discussed herein, and we find them to be
without merit, irrelevant, and/or moot.
To reflect the foregoing,
Decision will be entered
for respondent.
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