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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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