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and that she was not suffering from a mental or physical ailment
at the time she signed the joint returns or at the time she
requested relief. Thus, these additional factors do not weigh in
favor of relief for petitioner.
Taking into account all of the facts and circumstances, we
are not persuaded that it is inequitable to hold petitioner
liable for the deficiencies for the years in issue or that it was
an abuse of discretion for respondent to deny petitioner relief
under section 6015. 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