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statute to override the plain meaning. Halpern v. Commissioner,
96 T.C. 895, 899 (1991); Huntsberry v. Commissioner, 83 T.C. 742,
747-748 (1984).
1. Section 6015
Congress enacted section 6015 in the Internal Revenue
Service Restructuring and Reform Act of 1998 (RRA 1998), Pub. L.
105-206, sec. 3201, 112 Stat. 734, as a means of expanding relief
to innocent spouses. See H. Conf. Rept. 105-599, at 249-255
(1998), 1998-3 C.B. 747, 1003-1009; S. Rept. 105-174, at 55- 60
(1998), 1998-3 C.B. 537, 591-596; H. Rept. 105-364 (Part 1), at
60-62 (1997), 1998-3 C.B. 373, 432-434. Section 6015 replaced
section 6013(e) for any liability for tax arising after July 22,
1998, and any liability for tax remaining unpaid as of that date.
2. “Any determination”
We first address whether a credit or refund under section
6015(g) is a “determination” for purposes of the last sentence of
section 6015(a). We start with the statutory use of the word
“determination” in the context of community property laws and
relief from joint liability. Former section 6013(e) was added to
the Internal Revenue Code of 1954 by the Act of Jan. 12, 1971,
Pub. L. 91-679, sec. 1, 84 Stat. 2063. It provided limited
relief from joint return liability in paragraph (1) and included
in paragraph (2)(A) the following “Special rules”:
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