Debra Anne Banderas - Page 30



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          except for her weight, she was in good health during the 1997 and           
          1999 years at issue and until 2000 when her blood pressure began            
          rising.  The Court observes that petitioner was able to work                
          multiple jobs throughout much of the relevant period.  Thus,                
          while the Court does not doubt that petitioner bore substantial             
          stress on account of the difficult circumstances besetting her              
          family, the record does not enable us to find particular health             
          issues of a nature that would affect the balancing of her claim             
          for relief.  This factor, too, is neutral.                                  
               Accordingly, of those factors identified in the pertinent              
          revenue procedure, only one weighs clearly in favor of granting             
          relief.  The remainder are either negative or essentially                   
          neutral.  The Court is therefore unable to conclude that                    
          respondent’s denial of equitable relief under section 6015(f) was           
          an abuse of discretion.                                                     
              The Court has considered all other arguments made by the               
          parties and, to the extent not specifically addressed herein, has           
          concluded that they are without merit or are moot.  To reflect              
          the foregoing,                                                              

                                                  Decision will be entered            
                                             for respondent.                          










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