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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Section 6015, as amended, was originally enacted in 1998 to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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