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financial situation and the lack of economic hardship in this
case, we are not persuaded that it is inequitable to hold
petitioner liable for the underpayment for the year in issue or
that it was an abuse of discretion for respondent to deny
petitioner relief under section 6015(f). In reaching our
holding, we have considered all arguments made, and, to the
extent not mentioned, we conclude that they are irrelevant, moot,
or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: March 27, 2008