- 22 - 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--Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 NextLast modified: November 10, 2007