- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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