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petitioner requested relief as of the date of enactment of section
6015 (i.e., July 22, 1998). The Form 8857 sent by the IRS to
petitioner was the result of petitioner’s prior written and oral
requests for relief from liability for the 1989 tax liability.
Further, since refunds are included in the relief provided under
section 6015, we believe that a request for relief under section
6015 encompasses a request for a refund of tax to the extent
permitted under section 6015. We find, therefore, that petitioner
requested a refund of amounts paid/applied on the unpaid 1989 tax
liability as of July 22, 1998. Consequently, petitioner is
entitled to all amounts paid/applied on or after July 22, 1996.
The IRS credited petitioner’s 1992 and 1994-98 overpayments
against the 1989 tax liability as follows: $694.30 for 1992
(applied April 15, 1993), $991.78 for 1994 (applied April 15,
1995), $1,030 for 1995 (applied March 18, 1996), $523 for 1996
(applied March 10, 1997), $535 for 1997 (applied March 30, 1998),
and $2,001 for 1998 (applied April 15, 1999). As a result, claims
for refund for the 1992 and 1994-98 overpayments would have to have
been filed by the following dates:
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