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(Act). On February 1, 2007, respondent filed a response to the
Court’s January 10, 2007 Order (respondent’s response), and on
February 2, 2007, petitioner filed a response to that Order
(petitioner’s response).
Discussion
The Act amended section 6015(e)(1) to provide that the Court
may review the denial of relief under section 6015 by the Commis-
sioner of Internal Revenue (Commissioner) in any case where an
individual requested relief under section 6015(f). Tax Relief
and Health Care Act of 2006, div. C, sec. 408(a), Pub. L. 109-
432, 120 Stat. 2922, 3061. That amendment applies “with respect
to liability for taxes arising or remaining unpaid on or after
the date of the enactment of this Act.” Id. at 3062. The date
of the enactment of the Act was December 20, 2006.
In respondent’s response, respondent represents:
On December 21, 2005, petitioner fully paid the liabil-
ities for taxable years 1997, 2000 and 2003. * * *
* * * Thus, the liabilities for taxable years
1997, 2000 and 2003 did not remain unpaid as of the
date of enactment. As a result, the amendments to
I.R.C. � 6015(e) made by the Act * * * do not apply to
those years. Because the amendments do not apply to
taxable years 1997, 2000 and 2003, I.R.C. � 6015(e) as
it existed before the amendments and the law concerning
that statute apply to those years.
* * * * * * *
* * * As previously stated, in Billings v. Commis-
sioner, 127 T.C. 7 (2006), this Court held that it
lacked jurisdiction, under former I.R.C. � 6015(e), to
review respondent’s determination denying relief under
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Last modified: May 25, 2011