- 3 - case where an individual requested relief under section 6015(f). Tax Relief and Health Care Act of 2006, Pub. L. 109-432, div. C, sec. 408(a), 120 Stat. 2922, 3061. That amendment applies “with respect to liability for taxes arising or remaining unpaid on or after the date of the enactment of this Act.” Id. sec. 408(c), 120 Stat. 3062. The date of enactment of the Act was December 20, 2006. On January 10, 2007, the Court issued an Order (January 10, 2007 Order) in which it directed each party to address the Court’s jurisdiction in this case in light of the amendment that the Act made to section 6015(e)(1). Respondent filed a response to the Court’s January 10, 2007 Order (respondent’s response to the Court’s Order) in which respondent stated in pertinent part: 4. The balance of tax due for taxable years 1998 and 2002 was paid on April 27, 2006 pursuant to a levy issued to Anthony Arcodia, Jr., an attorney who was holding in escrow the proceeds of the sale of the former residence of the petitioner and the intervenor. 5. The tax liabilities, including interest and penalties, for which petitioner is seeking relief pursuant to I.R.C. § 6015(f) were both fully paid on April 27, 2006, which date is prior to the enactment of the Act. Thus, the liabilities at issue did not remain unpaid as of the date of enactment. As a result, the amendments to I.R.C. § 6015(e) made by the Act * * * do not apply to the present case. Because the amendments do not apply, I.R.C. § 6015(e) as it existed before the amendments and the law concerning that statute apply to the present case. 6. Before the amendments, I.R.C. § 6015(e), by its terms, only granted the Tax Court jurisdiction “[i]n thePage: Previous 1 2 3 4 5 6 7 8 NextLast modified: November 10, 2007