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liability are deemed to be payments at the time the credit is
made. Secs. 6402(a); 7422(d); Culpepper-Smith v. United States,
82 AFTR 2d 98-6212, 98-2 USTC par. 50,721 (E.D. Pa. 1998).
Accordingly, payment of petitioner’s 1993 tax liability was made
on February 23, 1998, and April 12, 1999. Section 6015 applies
to tax liabilities arising after or remaining unpaid on July 22,
1998. Internal Revenue Service Restructuring and Reform Act of
1998, Pub. L. 105-206, sec. 3201(g)(1), 112 Stat. 685, 740. In
this case, section 6015 applies only to that portion of
petitioner’s tax liability which remained unpaid after respondent
applied the first credit on February 23, 1998. Because the sole
basis for our jurisdiction in this case is section 6015(e), we
lack authority to grant relief with respect to the portion of the
1993 tax liability which was paid on February 23, 1998. Brown v.
Commissioner, T.C. Memo. 2002-187.
It is clear that the deficiency determined by respondent for
taxable year 1993 has been paid in full, and that the basis of
the relief respondent granted to petitioner was section 6015(c).
Consequently, section 6015(g)(3) bars any refund to petitioner as
a result of respondent’s determination that petitioner was
entitled to relief. Respondent’s determination letter does not
address petitioner’s alternative requests for relief under
section 6015(b) and (f), for which a refund would not be barred.
Nor was this issue addressed by petitioner in the petition or at
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