Diane C. Lincir - Page 7




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          1998 Act.  Section 3201(e)(1) of the 1998 Act repealed section              
          6013(e), the innocent spouse provisions which had been in effect            
          at the time of the trial in the 1989 case (112 Stat. 740);                  
          section 3201(a) of the 1998 Act enacted section 6015 (112 Stat.             
          734).  Section 3201(g)(1) of the 1998 Act provided in pertinent             
          part that both the section 6013(e) repeal and the section 6015              
          enactment “shall apply to * * * any liability for tax arising on            
          or before such date [the date of the enactment of the Act, July             
          22, 1998] but remaining unpaid as of such date.”  112 Stat. 740.            
               After petitioner and Lincir filed their notice of appeal               
          from our decision in the 1989 case and before that decision was             
          affirmed by the Court of Appeals, the Congress enacted the                  
          Consolidated Appropriations Act, 2001, which included the                   
          Community Renewal Tax Relief Act of 2000, Pub. L. 106-554, 114              
          Stat. 2763, 2763A-587, hereinafter sometimes referred to as the             
          2000 Act.  The 2000 Act made several changes to section 6015,               
          including the enactment of the present texts of section                     
          6015(g)(2) and section 6015(e)(1)(A).  Pars. (2) and (3)(B) of              
          sec. 313(a) of Appendix G of Pub. L. 106-554, 114 Stat. at 2763A-           
          640, 2763A-641.  The 2000 Act provided in pertinent part (sec.              
          313(f) of Appendix G of Pub. L. 106-554) that these changes                 
          “shall take effect on the date of the enactment of this Act.                
          [Dec. 21, 2000].”  114 Stat. at 2763A-643.                                  








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