Maria Rivera - Page 4

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          section 6015(c), petitioner is not entitled to a refund of her              
          income tax refund of $657 for 1998 or $872 for 1999.  Sec.                  
          6015(g)(1), (3).                                                            
               Petitioner also requested a refund of her 2001 overpayment.            
          Respondent did not apply this payment toward the 1988 or 1989 tax           
          liability.  Respondent transferred it to another agency to                  
          satisfy her delinquent child support obligation.                            
               Section 6015(g)(1) applies to credits or refunds only to the           
          extent attributable to the application of section 6015.                     
          Petitioner’s delinquent child support obligation, and                       
          respondent’s transfer of petitioner’s overpayment to another                
          agency, is unrelated to the application of section 6015.  See               
          sec. 6402(c).  Accordingly, section 6015(g) is inapplicable to              
          petitioner’s 2001 overpayment.                                              
               In reaching our holdings herein, we have considered all                
          arguments made by the parties, and to the extent not mentioned              
          above, we find them to be irrelevant or without merit.  To                  
          reflect the foregoing,                                                      


                                                  Decision will be entered            
                                             under Rule 155.                          











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