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King v. Commissioner, 115 T.C. 118 (2000). No relief may be
granted under section 6015 to a taxpayer who files a stand-alone
petition for such relief and whose liability was paid in full
before the effective date of section 6015. See Brown v.
Commissioner, T.C. Memo. 2002-187. Respondent asks us to decide,
however, the extent to which a taxpayer may qualify for relief
under section 6015 where the taxpayer’s liability arose prior to
the effective date of section 6015, but where only a portion of
the liability remained unpaid as of the date of enactment.
Recently, in Flores v. United States, 51 Fed. Cl. 49 (2001),
the Court of Federal Claims ruled on this issue. The court
considered and granted, under section 6015(f), relief with
respect to a taxpayer’s entire tax liability including the
portion of the liability that was paid prior to July 22, 1998,
the effective date of section 6015. The court stated:
Congress * * * intended the effective date provision to
be consonant with the remainder of the statute, thereby
allowing the innocent spouse relief of section 6015(b)
and (c), and with them the relief afforded by section
6015(f), to apply to any liability for a particular
taxable year providing it was not fully paid as of the
effective date. [Id. at 55.]
In support of its holding in Flores, the Court of Federal
Claims compared the effective date language of section 6015 to
the language of section 6511(a) that triggers the statute of
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