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not issue a notice of determination for 1995, 1996, 1997, or
1998. Petitioner timely petitioned this Court, asserting that
respondent erred by denying her relief under section 6015 for
1995, 1996, 1997, 1998, 1999, and 2000.
On November 28, 2006, respondent’s motion to dismiss for
lack of jurisdiction was filed. Respondent argues that we lack
jurisdiction under section 6015(e) over petitioner’s section
6015(f) claim for relief because respondent has not determined a
deficiency for any of the years at issue. Petitioner filed a
notice of objection to respondent’s motion.
In the Tax Relief and Health Care Act of 2006, Pub. L. 109-
432, div. C, sec. 408(a), (c), 120 Stat. 3061, 3062 (TRHCA
section 408), Congress amended section 6015(e) to confer
jurisdiction on this Court over stand-alone requests for
equitable relief under section 6015(f), effective for tax
liabilities arising or remaining unpaid on or after December 20,
2006. On April 19, 2007, respondent filed a supplement to his
motion to dismiss for lack of jurisdiction. Respondent concedes
that TRHCA section 408 grants us jurisdiction to review
respondent’s determination denying relief under section 6015(f)
for 1999 and 2000. Respondent argues, however, that we lack
jurisdiction to determine petitioner’s eligibility for relief
under section 6015(f) for 1995, 1996, 1997, and 1998 because the
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