- 10 -
pursuant to section 6015 which was not in effect until July 22,
1998. At no time on or after July 22, 1998, was Ms. Bacon
claiming, or will she be claiming, relief from joint and several
liability under section 6015 either in an administrative proceed-
ing before respondent or in a judicial proceeding before us.
Once respondent granted Ms. Bacon relief from joint and several
liability pursuant to former section 6013(e) prior to July 22,
1998, she had no liability for the assessed 1990 tax deficiency
on any date thereafter, including July 22, 1998. Ms. Bacon did
not have, and could not have had, any liability for the assessed
1990 tax deficiency which arose on or before July 22, 1998, when
Congress enacted section 6015, and which remained unpaid as of
that date. See id.
We conclude that section 6015 has no application to, and
does not govern, Ms. Bacon’s request for relief from joint and
several liability under former section 6013(e) and the adminis-
trative proceedings conducted by respondent that ultimately
resulted in respondent’s granting that relief to her prior to
July 22, 1998. Cf. King v Commissioner, 115 T.C. 118 (2000)
(section 6015 applies where spouse had a liability for tax
arising on or before July 22, 1998, which remained unpaid as of
that date and claimed relief from joint and several liability
under that section); Corson v. Commissioner, 114 T.C. 354 (2000)
(same). We further conclude (1) that petitioner did not have the
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011