Annette D. Goode-Parker - Page 12

                                       - 11 -                                         
          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               

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  

Last modified: May 25, 2011