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I.R.C. � 6015(f) when respondent has not determined a
deficiency. * * *
In petitioner’s response, petitioner
concedes that no tax liability remains unpaid as of
December 20, 2006. Accordingly, Petitioner concedes
that she is not seeking to invoke this Court’s juris-
diction under �6015(e)(1) as amended by the Tax Relief
and Health Care Act of 2006. She is seeking jurisdic-
tions [sic] under [section] 6015(e)(1) prior to amend-
ment.
In petitioner’s response, petitioner points out that the
United States Court of Appeals for the Second Circuit, where an
appeal in the instant case would normally lie, has not addressed
the issue of whether this Court has jurisdiction under section
6015(e)(1) prior to its amendment by the Act where a deficiency
has not been asserted. Petitioner seems to suggest in peti-
tioner’s response that, because the United States Court of
Appeals for the Second Circuit has not addressed that issue, the
Court should revisit and overrule its holding in Billings v.
Commissioner, 127 T.C. 7 (2006).
We held in Billings v. Commissioner, supra, that we lack
jurisdiction under section 6015(e)(1) prior to its amendment by
the Act to review a determination by the Commissioner denying
relief under section 6015(f) where a deficiency has not been
asserted. The Court is bound by the holding in Billings and
declines any invitation by petitioner to revisit and overrule
that holding.
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Last modified: May 25, 2011