Connie A. Washington - Page 36

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          limitations placed on a refund; section 6015(g) specifically                
          provides that no refunds can be made with respect to relief granted         
          under section 6015(c).  There is no such restriction for relief for         
          an unpaid tax granted under section 6015(f).                                
               Respondent contends that the court’s holding in Flores v.              
          United States, supra, leads to a result that Congress did not               
          intend.  Respondent notes that a taxpayer who paid the entire               
          liability would not be entitled to relief.  Respondent asserts that         
          only under a “strained interpretation” could Congress have intended         
          this result.  Therefore, respondent contends, Congress’s intent             
          must have been to allow relief only with respect to amounts that            
          remain uncollected after July 22, 1998.  We disagree.                       
               Congress obviously had to set a cutoff for claims for relief           
          under section 6015; otherwise, claims for refunds could go back for         
          decades.  We believe that Congress wanted to grant the broadest             
          relief, while providing for certainty in the settlement of tax              
          refund claims.  In setting the cutoff for claims for relief,                
          Congress treated claims related to liabilities for taxes that were          
          satisfied as of the date of enactment as settled as of that date.           
          Section 6015 relief is available for all claims related to tax              
          liabilities that were not settled as of July 22, 1998.  Further,            
          the disparity in the treatment of taxpayers who have paid the               
          liability in full as of July 22, 1998, and those who have partially         








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