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* * * * * * *
16. In addition, respondent is not bound by any
provisions relating to the 1990 tax liability contained
in petitioner’s divorce decree. See Pesch v. Commis-
sioner, 78 T.C. 100, 128-29 (1982) (respondent not
bound by agreement to which he is not a party).
The parties do not dispute that respondent granted Ms. Bacon
relief from joint and several liability with respect to the
assessed 1990 tax deficiency prior to July 22, 1998, the date on
which Congress (1) repealed section 6013(e) that was in effect
before that date (former section 6013(e)) and (2) enacted section
6015 relating to relief from joint and several liability. See
Internal Revenue Service Restructuring and Reform Act of 1998
(RRA 1998), Pub. L. 105-206, sec. 3201(a), (e)(1), (g)(1), 112
Stat. 685, 734, 740. Section 6015 generally applies to any
liability for tax arising after July 22, 1998, and any liability
for tax arising on or before such date but remaining unpaid as of
such date. See id. sec. 3201(g)(1). Read in the context of
section 6015, the liability for tax referred to in the foregoing
effective-date provision refers to the liability for tax of the
taxpayer claiming relief from joint and several liability.
Respondent alleges in the answer, and we find, (1) that
respondent must have granted Ms. Bacon relief from joint and
several liability pursuant to former section 6013(e) which was in
effect prior to July 22, 1998, when respondent granted Ms. Bacon
that relief, and (2) that respondent did not grant such relief
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