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(2000). Petitioner is not entitled to relief for 1988 under
section 6015 because the Browns’ 1988 tax liability was paid in
full on May 18, 1998, which is before July 22, 1998. Miller v.
Commissioner, 115 T.C. 582, 587 (2000), affd. 21 Fed. Appx. 160
(4th Cir. 2001); Mlay v. IRS, 168 F. Supp. 2d 781, 785 (S.D. Ohio
2001).
Congress expanded the relief available to joint filers by
repealing section 6013(e) in 1998 and enacting section 6015. RRA
sec. 3201(a), (e)(1), 112 Stat. 734, 740. Section 6015 applies
to any liability for tax arising on or before July 22, 1998, but
remaining unpaid as of that date. RRA sec. 3201(g)(1), 112 Stat
740. However, petitioner’s tax was paid in full before the
effective date of section 6015. Thus, her claim is governed by
section 6013(e).1
We are aware of no provision in the Internal Revenue Code
which allows us to grant relief under section 6013(e) to a
taxpayer, such as petitioner in this case, who filed a “stand-
1 The four requirements for relief under sec. 6013(e) are:
(1) A joint return was filed for the year at issue; (2) the
return contained a substantial understatement of tax attributable
to grossly erroneous items of the other spouse; (3) the spouse
seeking relief establishes that, in signing the return, he or she
did not know, and had no reason to know, of the substantial
understatement; and (4) it would be inequitable to hold the
spouse seeking relief liable for the substantial understatement.
Sec. 6013(e)(1).
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