Yvonne E. Thurner - Page 11

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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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