Nancy M. O'Neill, Petitioner, and Robert B. Wollow, Intervenor - Page 11

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          satisfy the liability with her IRA is not sufficient to qualify             
          petitioner for relief under section 6015(f).                                
               After considering all of the facts and circumstances, we               
          conclude that respondent’s decision to deny relief from joint and           
          several liability was not an abuse of discretion.                           
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          
































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