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filed.2 Pursuant to section 7463(b), the decision to be entered
is not reviewable by any other court, and this opinion shall not
be treated as precedent for any other case.
Petitioner seeks relief from joint and several liability for
Federal income taxes for the years 1990 through 1995 with respect
to joint returns she filed with her former husband, David Reeves
Scott (Mr. Scott). Respondent determined that petitioner is not
entitled to relief under section 6015(b) or (c) but is entitled
to relief for one-half ($13,476) of the total liabilities under
section 6015(f). Petitioner filed a petition seeking review of
respondent’s determination. The only issue for decision is
whether petitioner is entitled to full relief under section
6015(f) for all of the tax liabilities.3
2Unless otherwise indicated, subsequent section references
are to the Internal Revenue Code in effect for the years at
issue, and Rule references are to the Tax Court Rules of Practice
and Procedure.
3The Tax Relief and Health Care Act of 2006, Pub. L. 109-
432, div. C, sec. 408, 120 Stat. 3061, amended sec. 6015(e)(1) to
give the Tax Court jurisdiction to determine the appropriate
relief available to a taxpayer under sec. 6015, including relief
under sec. 6015(f) in cases where no deficiency has been
determined for the tax year. The amendment applies with respect
to liability for taxes arising or remaining unpaid on or after
Dec. 20, 2006, the date of enactment. Id. sec. 408(c), 120 Stat.
3062. The liabilities at issue in this case remain unpaid, and
we have jurisdiction to determine the relief available to
petitioner under sec. 6015(f) for all years in issue.
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