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decision representing a concession that she has no liability for
any amount of the deficiency or penalty in dispute. Respondent
made no determination whether petitioner wife qualifies for
relief under section 6015(b). With leave of the Court,
petitioner wife amended her petition, requesting the Court to
require respondent to make a determination under former section
6013(e) and/or section 6015(b).9
The controversy before the Court concerns petitioner wife’s
liability for the deficiency respondent determined for taxable
year 1990. Respondent’s concession under section 6015(c)
relieves petitioner wife of all liability for taxable year 1990
and resolves the controversy between her and respondent that is
before us. Cf. LTV Corp. v. Commissioner, 64 T.C. 589, 593
(1975). A decision regarding petitioner wife’s eligibility for
relief under section 6015(b) would amount to an advisory opinion
and would contravene the “sound principle of judicial
administration that courts will not gratuitously decide complex
9 On brief, petitioner wife does not press the issue of her
entitlement to relief under former sec. 6013(e), and we deem her
to have conceded it. In any event, since the disputed tax
liability arose before July 22, 1998, but remained unpaid as of
that date, former sec. 6013(e) is no longer effective with
respect to the instant case, which is governed instead by the
provisions of sec. 6015. See Internal Revenue Service
Restructuring and Reform Act of 1998, Pub. L. 105-206, sec.
3201(e)(1), 112 Stat. 734.
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