Nita B. Leissner - Page 8
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or requests for relief filed on or after July 18, 2002. Sec.
1.6015-9, Income Tax Regs. These regulations are not applicable
in the instant case because petitioner requested relief before
July 18, 2002.
Subsequent to the expiration of the briefing schedule in
this case, this Court decided Washington v. Commissioner, supra,
in which we held that section 6015(f) applies to the full amount
of any preexisting tax liability for a particular taxable year,
if any part of that liability remains unpaid as of the date of
enactment, and not just to portions of tax liability that remain
unpaid after July 22, 1998. Consequently, if any part of the tax
liability for a particular year remained unpaid as of July 22,
1998, petitioner is entitled to a refund of the entire amount
that was paid and applied to the tax liability of that particular
year, even if such amount was paid prior to July 22, 1998.
IV. Parties’ Contentions Regarding the Amount of Petitioner’s
Tax Liabilities Remaining Unpaid as of July 22, 1998
The parties stipulated that on July 22, 1998, there was an
outstanding income tax liability for petitioner’s 1986 tax year.
The parties also stipulated that the application by the Internal
Revenue Service of $11,270.42 on January 7, 1997, to the 1987
liability fully paid the tax, penalties, and interest due for the
1987 tax year. The only amount remaining unpaid for 1987 after
the application of said amount was a $32 lien filing fee.
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