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liability is attributable to such understatement.” (Emphasis
supplied.) That language clearly relieves the spouse of all
liability for the taxable year attributable to the understatement;
it suggests that Congress intended that the provision “should apply
to the entire taxable year and the entire tax liabilities
associated therewith”. Flores v. United States, supra at 55.
Further, there is solid precedent in decisions that treat an
income “tax liability for a particular year as being unitary and
‘paid’ only when fully collected.” Id.; see, e.g., Union Trust Co.
v. United States, 70 F.2d 629, 630 (2d Cir. 1934) (“the entire tax
liability is unitary and not discharged until paid in full”); see
also Flora v. United States, 362 U.S. 145 (1960) (income tax is
imposed on a unitary basis that precludes suits based on partial
payment). We see no reason why RRA 1998, section 3201(g), should
not be similarly interpreted, “particularly in light of * * * [the]
court’s obligation to construe liberally the innocent spouse
amendments as curative legislation.” Flores v. United States,
supra at 56.
Further, we note that section 6015(f) provides that if “it is
inequitable to hold the individual liable for any unpaid tax * * *
the Secretary may relieve such individual of such liability.” The
legislative history indicates that “unpaid tax” referred to in
section 6015(f) does not refer to the amount that is not paid when
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