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B. Assessment and Payment of the Browns’ 1988 Tax Liability
Respondent mailed the Browns a notice of deficiency for
1988-90 on March 25, 1994. In it, respondent determined that the
compensation that Brown had reported as income from self-
employment was wages. Neither petitioner nor Brown filed a
petition in the Tax Court in response to the notice of
deficiency. On August 10, 1994, respondent assessed taxes based
on the March 25, 1994, notice of deficiency.
Respondent applied the Browns’ overpayments of tax for 1994,
1995, 1996, and 1997 to their 1988 tax liability as follows:
Year of Date Amount
overpayment applied applied
1994 May 1, 1995 $179
1995 Apr. 29, 1996 1,801
1994 May 20, 1996 1,196
1996 Apr. 21, 1997 2,507
1997 May 18, 1998 3,054
The Browns’ 1988 tax liability was paid in full on May 18,
1998.
OPINION
Petitioner contends that she is entitled to relief from
joint and several liability for 1988 under section 6015. We
disagree. Section 6015 does not apply to any liability for tax
arising before July 22, 1998, except to the extent it remained
unpaid as of that date. Internal Revenue Service Restructuring
and Reform Act of 1998 (RRA), Pub. L. 105-206, sec. 3201(g)(1),
112 Stat. 740; Butler v. Commissioner, 114 T.C. 276, 281-282
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