Thomas Corson and Judith Corson - Page 10




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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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