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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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