- 3 - 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, 281-282Page: Previous 1 2 3 4 5 Next
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