- 5 - 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 TaxPage: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007