Connie A. Washington - Page 29

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          not entitled to relief under section 6015 if the liability was paid         
          in full on or before July 22, 1998.  Miller v. Commissioner, 115            
          T.C. 582, 587 (2000), affd. 21 Fed. Appx. 160 (4th Cir. 2001);              
          Brown v. Commissioner, T.C. Memo. 2002-187.                                 
               For the reasons set forth below, we do not agree with                  
          respondent’s position that only the portion of tax remaining                
          uncollected on July 22, 1998, is subject to the provisions of               
          section 6015(f).                                                            
               In interpreting a statute, courts are guided by principles of          
          statutory construction, including the following:  (1) Unless                
          otherwise defined, words will be interpreted as taking their                
          ordinary, contemporary, and common meaning; and (2) unless the              
          statute otherwise dictates, where Congress uses terms that have             
          acquired a settled meaning under the common law, a court must infer         
          that Congress means to incorporate the established meaning of the           
          terms.  Moreover, we are mindful that section 6015 was designed “to         
          correct perceived deficiencies and inequities”, and it is well              
          settled law that “curative legislation should be liberally                  
          construed to effectuate its remedial purpose.”  Flores v. United            
          States, supra at 53.                                                        
               The precise definition of the word “remain” varies somewhat            
          depending on its context.  According to Webster’s Third New                 
          International Dictionary (1993), the word “remain”, as a verb, can          
          mean “to be a part not destroyed, taken away, or used up : be still         






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