Stacy Lee Gonce - Page 13

                                       - 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  13

Last modified: March 27, 2008