Patricia H. Devlin - Page 10

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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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