- 29 - 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 stillPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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