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jurisdiction over nondeficiency section 6015(f) cases. We
reasoned that when Congress added the phrase “against whom a
deficiency has been asserted” to section 6015(e), it removed our
jurisdiction. Billings, 127 T.C. at 16-17. The recent amendment
to section 6015(e) restores our jurisdiction over cases like Ms.
Goode-Parker’s by inserting the phrase "or in the case of an
individual who requests equitable relief under subsection (f)" in
section 6015(e). Tax Relief and Health Care Act of 2006, Pub. L.
109-432, div. C, sec. 408(a), 120 Stat. 3061. But this amendment
doesn’t help her, because it is effective only for liabilities
remaining unpaid after its date of enactment, which was December
20, 2006. Id. sec. 408(c), 120 Stat. 3062. Her tax liability
was paid in full by November 2002, and so
An order will be entered
dismissing the case for lack of
jurisdiction.
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Last modified: May 25, 2011