Debra Bock - Page 3

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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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