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provides for equitable relief in cases where relief is not
available to a taxpayer under section 6015(b) or (c).
Petitioners invoked the Court’s jurisdiction in these cases
under section 6015(e)(1)(A)(i)(II). The latter provision permits
a taxpayer to file a petition with the Court if 6 months have
elapsed since the taxpayer filed his or her election for relief
with the Commissioner and the Commissioner has not issued a final
determination granting or denying relief.
B. Taxable Year 1980
RRA 1998 sec. 3201(g), 112 Stat. 740, states in unambiguous
terms that relief under section 6015 is available only with
respect to any liability for tax arising after July 22, 1998, and
any liability for tax arising on or before July 22, 1998, but
remaining unpaid as of such date. There is no dispute that
petitioners’ tax liability for 1980 arose before July 22, 1998,
and that such liability was fully paid before that date.
Consequently, we hold that respondent is entitled to judgment as
a matter of law that petitioners are not eligible for relief
under section 6015 with regard to their tax liability for 1980.
See Washington v. Commissioner, supra.
C. Taxable Years 1981, 1990, and 1992
The judicial doctrine of res judicata provides that, when a
court of competent jurisdiction enters a final judgment on the
merits of a cause of action, the parties to the action are bound
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