- 3 - (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 underPage: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011