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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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