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and “determine” do not appear in subsection (g)(1), which
provides that a “credit or refund shall be allowed or made to the
extent attributable to the application of this section.” Section
6015(g)(2) provides: “The exception contained in the preceding
sentence shall not apply if the court determines that the
individual participated meaningfully in such prior proceeding.”
4. History of Section 6015(g)
In 1998, paragraph (3)(A) of section 6015(e), as amended by
a technical correction in the Omnibus Consolidated and Emergency
Supplemental Appropriations Act, 1999, Pub. L. 105-277, sec.
4002(c)(2), 112 Stat. 2681-906 (1998), provided as follows:
(3) Applicable rules.--
(A) Allowance of credit or refund.--
Except as provided in subparagraph (B),
notwithstanding any other law or rule of law
(other than section 6512(b), 7121, or 7122),
credit or refund shall be allowed or made to
the extent attributable to the application of
subsection (b) or (f).
The technical corrections in the Community Renewal Tax Relief Act
of 2000, Pub. L. 106-554, sec. 313, 114 Stat. 2763A-640, 2763A-
641, amended subsection (e)(3) by redesignating subsection (g) as
(h) and adding new subsection (g)(1), which provides:
SEC. 6015(g). Credits and Refunds.--
(1) In general.--Except as provided in
paragraphs (2) and (3), notwithstanding any
other law or rule of law (other than section
6511, 6512(b), 7121, or 7122), credit or
refund shall be allowed or made to the extent
attributable to the application of this
section.
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