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of “unpaid” is “not paid”. Webster’s Third New International
Dictionary (1993). The word “paid” is a form of the word “pay”,
which “is a general term, usually lacking particular connotation”.
Id. The word “paid” can mean “gave a recompense”, “made payment”,
or “discharged an obligation”; it can be synonymous with
“compensated”, “remunerated”, “satisfied”, “reimbursed”,
“indemnified”, “recompensed”, or “repaid”. Id.
We believe that, when used to describe the continuing state of
a liability for tax in the provision under consideration, the word
“paid” means “satisfied” and that the word “unpaid” means “not
satisfied”. Id. A liability for tax “remaining unpaid as of the
effective date” is a liability for tax that continues to be
unsatisfied as of the applicable date. A liability is not
satisfied until it is paid in full, id.; ergo, a liability remains
unsatisfied or unpaid until it is paid in full.
Other provisions of section 6015 indicate that Congress
intended the expanded relief provided by section 6015 to apply
retroactively to the entire preexisting liability, rather than to
the portion of a preexisting liability that had been uncollected as
of the date of enactment. Flores v. United States, 51 Fed Cl. at
54. For example, section 6015(b) provides that if a spouse elects
and qualifies for relief under that section, then the spouse “shall
be relieved of liability for tax (including interest, penalties,
and other amounts) for such taxable year to the extent such
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