Teresa G. Butner - Page 22




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          3061.  The amendment applies “with respect to liability for taxes           
          arising or remaining unpaid on or after the date of the enactment           
          of this Act.”  Id. sec. 408(c), 120 Stat. 3062.  The date of                
          enactment of the Act was December 20, 2006.                                 
               After the Act amended section 6015(e)(1), we issued an Order           
          in the instant case, in which we directed each party to file a              
          response to that Order addressing the jurisdiction of the Court             
          over this case in light of the amendment that the Act made to               
          section 6015(e)(1).  Petitioner filed no such response.  Respon-            
          dent filed a response in which respondent stated that the Court             
          has jurisdiction to review respondent’s denial of relief under              
          section 6015(f) with respect to each of the taxable years 1994,             
          1995, 1998, and 1999.  That is because, according to respondent,            
          the liability due for each of those years remained unpaid as of             
          December 20, 2006, the date of enactment of the Act.                        
               We hold that we have jurisdiction over the instant case to             
          review respondent’s denial of relief under section 6015(f) with             
          respect to each of the taxable years 1994, 1995, 1998, and 1999.            
               We consider now respondent’s denial of relief under section            
          6015(f) to petitioner.  Section 6015(f) provides:                           
               SEC. 6015.  RELIEF FROM JOINT AND SEVERAL LIABILITY ON                 
                           JOINT RETURN.                                              
                  *       *       *       *       *       *       *                   
                    (f).  Equitable Relief.--Under procedures pre-                    
               scribed by the Secretary, if--                                         







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