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Ms. Hopkins should not now be permitted to reopen the
question of her liability in the current adversary
proceedings on the grounds that she was an “innocent
spouse.” Permitting her to do so would undermine the
very purpose of entering into a closing agreement in
the first place. [Id. at 733.]
The Court of Appeals decided that case in the context of a claim
for relief under former section 6013(e). Relief under section
6015 was not available at the time that case was decided on June
17, 1998. Following the decision of the Court of Appeals for the
Ninth Circuit in Hopkins v. United States (In re Hopkins), 146
F.3d 729, section 6015 was enacted and provided retroactive
relief for tax liabilities remaining unpaid as of its effective
date. Petitioner argues that, despite her signing the closing
agreement, she is entitled to claim relief under section 6015.
In interpreting section 6015, our purpose is to give effect
to Congress’s intent. Ewing v. Commissioner, 118 T.C. 494, 503
(2002); Fernandez v. Commissioner, 114 T.C. 324, 329 (2000). We
begin as always with the statutory language, and we interpret
that language with reference to the legislative history primarily
to learn the purpose of the statute and to resolve any ambiguity
in the words contained in the language. Ewing v. Commissioner,
supra at 503.
Section 6015 does not address the issue of unpaid taxes
arising from a section 7121 closing agreement. Section 6015
makes no explicit reference to closing agreements except for a
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