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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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