- 66 -
that revenue procedure also 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 that weigh
in favor of granting relief under section 6015(f) and that are
not set forth in sections 4.02(1) and 4.03(1) of Revenue Proce-
dure 2000-15.
Based upon our examination of the entire record before us,
we find that petitioner has failed to carry her burden of showing
that respondent abused respondent’s discretion in denying her
relief under section 6015(f) with respect to the unpaid 1998
liability.
We have considered all of the parties’ arguments and conten-
tions 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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