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Restructuring and Reform Act of 1998 (RRA), Pub. L. 105-206, sec.
3201(a), (e)(1), 112 Stat. 734. On August 3 and 18, 1998,
petitioner filed administrative elections for relief from joint
liability pursuant to section 6015(b) and (c), respectively. The
Court suspended the briefing schedule to provide respondent an
opportunity to respond to petitioner’s administrative elections.
On January 13, 1999, respondent notified petitioner that she
is entitled to relief from joint liability pursuant to section
6015(c) and mailed her a proposed decision representing a
concession that she has no liability for any amount of the
deficiency in dispute. Respondent made no determination whether
petitioner qualified for relief under section 6015(b).
On January 25, 1999, petitioner advised the Court that she
agreed with respondent’s concession of the entire deficiency
against her pursuant to section 6015(c) but that she would not
agree to respondent’s proposed decision unless respondent also
responded to her election under section 6015(b).
With leave of the Court, on March 17, 1999, petitioner filed
an amendment to petition, in which she requested the Court to
require respondent to make a determination as to her eligibility
for relief from joint liability under former section 6013(e) and
section 6015(b). On March 26, 1999, respondent filed an answer
to petitioner’s amendment to petition. The Court then directed
the parties to file opening and answering briefs.
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