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In September 1998, Sylvia and respondent entered into a
stipulation resolving all issues with respect to Sylvia except
Sylvia’s entitlement to relief from joint liability on the joint
returns. The settlement stated: “Without considering the
innocent spouse provisions of � 6013(e), there are deficiencies
in income tax due from Ms. Johnson for the taxable years 1979 and
1980 in the amounts of $44,017 and $21,657, respectively.” The
stipulation further provided that Sylvia was not liable for
additions to tax under section 6653(a) for 1979 and 1980. It
further provided:
Without considering the innocent spouse provisions of
I.R.C. � 6013(e), $44,017 and $21,657 of the deficiencies
in tax due from Ms. Johnson for the taxable years 1979
and 1980, respectively, are substantial underpayments
attributable to tax motivated transactions, for purposes
of computing the interest payable with respect to such
amounts, pursuant to I.R.C. � 6621(c).
On July 22, 1998, the RRA was enacted. The statute, among
other things, revised and expanded the relief from joint
liability available to spouses filing joint returns. The
relevant provisions of the RRA generally apply to any liability
for tax arising after July 22, 1998, and any liability for tax
arising on or before that date and remaining unpaid on that date.
On November 18, 1998, except for the provisions relating to
relief from joint liability, an identical stipulation was filed
in regard to the Hale Exemption Trust.
On May 1, 2000, the Court filed a second stipulation of
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