- 13 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13Last modified: March 27, 2008