Nita B. Leissner - Page 7

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               credit or refund shall be allowed or made to the extent                
               attributable to the application of this section.                       
          Thus, any refund available to petitioner is limited to the extent           
          attributable to the application of section 6015, and subject to             
          any limitation imposed by sections 6511, 6512(b), 7121, or 7122.            
          II.  Parties’ Contentions Regarding the Applicability of Section            
          6015(f)                                                                     
               The parties stipulated that petitioner would be eligible for           
          relief under section 6015(f) if relief were not barred as                   
          described in section 6015(g).  Petitioner argues that section               
          6015(f) relief is “available for the entire tax liability of any            
          tax year for which any portion was unpaid on the date of                    
          enactment.”  Petitioner contends that she is entitled to a refund           
          of the amount levied from the Merrill Lynch account and applied             
          to the 1986 and 1987 tax liabilities.  Petitioner argues that she           
          is entitled to such a refund even though the amount was paid                
          prior to July 22, 1998, the effective date of section 6015(f).              
               Respondent argues that section 6015(f) applies only to (1)             
          liabilities arising after July 22, 1998, and (2) amounts paid               
          after July 22, 1998.  Respondent contends that petitioner is not            
          entitled to a refund of the levied amounts because they were paid           
          prior to July 22, 1998.                                                     
          III.  Analysis of the Applicability of Section 6015(f)                      
               On July 17, 2002, respondent adopted regulations under                 
          section 6015.  These regulations are applicable for all elections           





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