- 9 - preponderance of the evidence that she did not meaningfully participate in the prior proceedings. Huynh v. Commissioner, T.C. Memo. 2006-180; Monsour v. Commissioner, T.C. Memo. 2004- 190. A taxpayer who has filed a joint return may seek relief from joint and several liability by following procedures established in section 6015. Section 6015 may apply to a tax liability that arose after July 22, 1998, and also to a tax liability that arose on or before such date and remained unpaid as of July 22, 1998. See Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3201(g)(1), 112 Stat. 740; Vetrano v. Commissioner, 116 T.C. 272, 277 (2001). The doctrine of res judicata provides that, when a court of competent jurisdiction enters a final judgment in a cause of action, the parties are bound “‘not only as to every matter which was offered and received * * * but as to any other admissible matter which might have been offered for that purpose.’” Commissioner v. Sunnen, 333 U.S. 591, 597 (1948) (quoting Cromwell v. County of Sac, 94 U.S. 351, 352 (1877)). The doctrine also applies where the Court’s final decision was based on an agreement between the parties. See United States v. Bryant, 15 F.3d 756, 758 (8th Cir. 1994). Section 6015(g)(2) provides that, in the case of an election under section 6015(b) or (c) for any taxable year that is thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 NextLast modified: November 10, 2007