Nita B. Leissner - Page 8

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          or requests for relief filed on or after July 18, 2002.  Sec.               
          1.6015-9, Income Tax Regs.  These regulations are not applicable            
          in the instant case because petitioner requested relief before              
          July 18, 2002.                                                              
               Subsequent to the expiration of the briefing schedule in               
          this case, this Court decided Washington v. Commissioner, supra,            
          in which we held that section 6015(f) applies to the full amount            
          of any preexisting tax liability for a particular taxable year,             
          if any part of that liability remains unpaid as of the date of              
          enactment, and not just to portions of tax liability that remain            
          unpaid after July 22, 1998.  Consequently, if any part of the tax           
          liability for a particular year remained unpaid as of July 22,              
          1998, petitioner is entitled to a refund of the entire amount               
          that was paid and applied to the tax liability of that particular           
          year, even if such amount was paid prior to July 22, 1998.                  
          IV.  Parties’ Contentions Regarding the Amount of Petitioner’s              
          Tax Liabilities Remaining Unpaid as of July 22, 1998                        
               The parties stipulated that on July 22, 1998, there was an             
          outstanding income tax liability for petitioner’s 1986 tax year.            
          The parties also stipulated that the application by the Internal            
          Revenue Service of $11,270.42 on January 7, 1997, to the 1987               
          liability fully paid the tax, penalties, and interest due for the           
          1987 tax year.  The only amount remaining unpaid for 1987 after             
          the application of said amount was a $32 lien filing fee.                   






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