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issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
Petitioner seeks review of respondent’s notice of
determination dated January 12, 2005, denying her relief from
joint and several liability under section 6015(c) and (f) for
1995, 1996, and 1997.1 After a concession,2 the issues for
decision are: (1) Whether the doctrine of res judicata under
section 6015(g)(2)3 bars petitioner from raising relief under
section 6015 for 1995 and 1996, and if not, whether petitioner is
entitled to relief from joint and several liability under section
6015(c) for 1995 and 1996; and (2) whether petitioner is entitled
to relief from joint and several liability under section 6015(c)
for 1997.
1The Internal Revenue Service Restructuring and Reform Act
of 1998 (RRA 1998), Pub. L. 105-206, sec. 3201(a), 112 Stat. 734,
repealed sec. 6013(e) and replaced it with sec. 6015. Sec. 6015
applies to any tax arising after July 22, 1998, and to any
liability for tax arising on or before July 22, 1998, and unpaid
as of that date. RRA 1998 sec. 3201(g), 112 Stat. 740. Sec.
6015, therefore, applies in this case.
2Petitioner concedes that she is not entitled to relief from
joint and several liability under sec. 6015(f) for 1995, 1996,
and 1997.
3The Consolidated Appropriations Act, 2001, Pub. L. 106-544,
app. G, sec. 313(a)(2)(A), 114 Stat. 2763A-640 (2000), enacted on
Dec. 21, 2000, redesignated subsec. (g) of Code sec. 6015 as
subsec. (h) and inserted the language of Code sec. 6015(e)(3)(B)
in new subsec. (g)(2). The effective date of this change is the
date of enactment. Id. sec. 313(f), 114 Stat. 2763A-643.
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