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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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