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under section 6015(f) with respect to the unpaid liabilities for
the years at issue.12
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 petitioner.
12Our finding is the same regardless whether we limit our
consideration to respondent’s administrative record with respect
to petitioner’s taxable years at issue.
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Last modified: November 10, 2007