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determination of another taxpayer” and, hence, concluded that “A
taxpayer therefore lacks standing to challenge the ‘innocent
spouse’ relief granted to his or her spouse.”
Consequently, under prior law it is clear that Thomas’s
objection here would not furnish grounds for denying respondent’s
motion. We thus turn to whether changes wrought by the
Restructuring Act demand a different result.
B. Present Innocent Spouse Law
The Restructuring Act revised and expanded the relief
available to joint filers by striking subsection (e) from section
6013 and by promulgating in its place a new section 6015. See
Restructuring Act sec. 3201(a), (e)(1), 112 Stat. 734, 740.
Section 6015 was also given retroactive effect to the extent that
it was made applicable to any liability for tax arising after
July 22, 1998, and to any liability for tax arising on or before
such date but remaining unpaid as of July 22, 1998. See
Restructuring Act sec. 3201(g)(1), 112 Stat. 740.
Whereas section 6013(e) had offered only a single avenue of
relief, based on a spouse’s lack of knowledge or reason to know
of a substantial understatement, section 6015 authorizes three
types of relief. Subsection (b) provides a form of relief
available to all joint filers and similar to, but less
restrictive than, that previously afforded by section 6013(e).
Subsection (c) permits a taxpayer who has divorced or separated
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