Zenobia Elisia Clary Ziegler - Page 6

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          for a particular taxable year, if any of that liability remains             
          unpaid as of July 22, 1998, and not just to portions of the tax             
          liability that remain unpaid after July 22, 1998, the date of               
          enactment of the Internal Revenue Service Restructuring and                 
          Reform Act of 1998 (RRA 1998), Pub. L. 105-206, sec. 3201(g)(1),            
          112 Stat. 740.  In so doing, we emphasized that “Section 6015               
          applies ‘to any liability for tax arising after the date of the             
          enactment of this Act [July 22, 1998] and any liability for tax             
          arising on or before such date but remaining unpaid as of such              
          date.’”   Washington v. Commissioner, supra at 154 (quoting RRA             
          1998 sec. 3201(g)).  We held that section 6015(g) permits a                 
          refund where relief from liability is granted under section                 
          6015(f) and rejected the Commissioner’s argument that the                   
          reference to “unpaid tax” contained in section 6015(f) operates             
          to restrict relief under section 6015(f) to the portion of the              
          tax liability in question that remained unpaid as of July 22,               
          1998.  Id. at 159.                                                          
               On May 14, 2003, we issued an order remanding this case to             
          respondent to reconsider petitioner’s application for relief in             
          light of our opinion in Washington and to report to us regarding            
          the result of that reconsideration.  Pursuant to our order,                 
          respondent issued a determination dated July 3, 2003, concluding            
          that petitioner did not qualify for relief under section 6015(f)            
          and Rev. Proc. 2000-15, supra.  On August 7, 2003, the parties              

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