Hale Exemption Trust - Page 4




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          settlement between Sylvia and respondent.  That settlement                  
          provided that after the application of section 6015(c) there was            
          no deficiency due from or overpayment due to Sylvia for 1979, and           
          that the provisions of section 6621(c), formerly section 6621(d),           
          were not applicable to Sylvia for 1979.  It further provided that           
          no relief was granted pursuant to section 6015(c) for 1980 and              
          that the original stipulation of settlement still applied.                  
               Sharon Hale refused to sign a stipulated decision based on             
          the second stipulation of settlement between Sylvia and                     
          respondent and the previous stipulation between the Hale                    
          Exemption Trust and respondent.                                             
                                     Discussion                                       
               We have previously analyzed the effect of the enactment of             
          section 6015 on the prior law under section 6013(e).  See King v.           
          Commissioner, 115 T.C. 118 (2000); Corson v. Commissioner, 114              
          T.C. 354 (2000); Charlton v. Commissioner, 114 T.C. 333 (2000);             
          Fernandez v. Commissioner, 114 T.C. 324 (2000); Butler v.                   
          Commissioner, 114 T.C. 276 (2000).  We need not reiterate that              
          analysis here.                                                              
               Sharon Hale’s objection to respondent’s motion for entry of            
          decision is that section 6015 altered the prior law and that                
          section 6015 gives her the right to contest respondent’s                    
          determination to grant section 6015 relief to the electing spouse           
          in this Court.  Sharon Hale finds such a right in section                   






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