John F. Heyse - Page 4




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               On August 9, 1999, petitioner requested relief with respect            
          to the 1993 liability under section 6015(b), (c), and (f).  On              
          March 27, 2001, respondent issued a notice of determination                 
          granting petitioner partial relief pursuant to section 6015(c).             
          The notice stated that petitioner had requested relief in the               
          amount of $24,093, that relief had been granted in the amount of            
          $20,367, and that there was tax remaining of $3,729.3  The notice           
          also stated that refunds were not allowed with respect to section           
          6015(c) relief.                                                             
               Petitioner filed a petition in this Court seeking relief               
          pursuant to section 6015.  He requests that this Court:                     
               determine that Petitioner is eligible for relief under                 
               Section 6015 in the amount of $20,367.00 and direct the                
               Internal Revenue Service to issue a refund to Petitioner in            
               the amount of $20,367.00, together with statutory interest             
               thereon, pursuant to Section 6015 of the Internal Revenue              
               Code.                                                                  
          Respondent argues that any refund is barred by section                      
          6015(g)(3).                                                                 
               Section 6015, as amended, was originally enacted in 1998 to            
          replace former section 6013(e).  Internal Revenue Service                   

          2(...continued)                                                             
          trial that the excess was applied to assessed interest.  Neither            
          party specifically addressed this point, but respondent                     
          presumably has relieved petitioner from liability for any                   
          remaining unpaid interest.                                                  
          3It is unclear what the basis for this determination was,                   
          however, because sec. 6015(c) relief applies to assessed                    
          deficiencies.  Sec. 6015(c)(1).  The deficiency in petitioner’s             
          case was only $15,479.                                                      





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