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September 19, 2006, respondent contended that in light of
Billings v. Commissioner, supra, the Court lacked jurisdiction
over this case. Petitioner’s response contended that the Court
possessed the requisite authority to enter the stipulated
decision in this case. The Court received no response from
intervenor.
In the Tax Relief and Health Care Act of 2006, Pub. L. 109-
432, div. C, sec. 408, 120 Stat. 3061, Congress reinstated our
jurisdiction to review the Commissioner’s determinations under
section 6015(f) with respect to tax liability remaining unpaid on
or after December 20, 2006. By Order dated January 10, 2007, we
ordered the parties, including intervenor, to file responses
addressing the Court’s jurisdiction in this case. In his
response filed February 5, 2007, respondent indicated that
petitioner’s liability for tax year 2000 remained unpaid as of
December 20, 2006, so that under the recent amendment to section
6015, this Court has jurisdiction over this case. Similarly, in
her response filed January 9, 2007, petitioner maintained that
this Court has jurisdiction over this case. The Court has
received no response from intervenor.
Discussion
It is undisputed that petitioner’s liability for tax year
2000 remained unpaid as of December 20, 2006. Accordingly,
pursuant to the recent amendment to section 6015 by the Tax
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Last modified: November 10, 2007