- 7 - that, pursuant to a levy issued to Anthony Arcodia, Jr. (Mr. Arcodia), an attorney who was holding in escrow the proceeds of the sale of the former residence of petitioner and the inter- venor, Mr. Arcodia paid on April 27, 2006, the liability for tax with respect to, inter alia, each of petitioner’s taxable years 1998 and 2002. Although petitioner makes various claims in petitioner’s response to the Court’s Order that that levy was unlawful, the fact remains that there was no liability for tax for petitioner’s taxable year 1998 or her taxable year 2002 that remained unpaid on or after December 20, 2006, the date of the enactment of the Act.2 We hold that the amendment to section 6015(e)(1) that the Act made does not apply in the instant case. We further hold that we do not have jurisdiction over the instant case to deter- mine whether petitioner is entitled to relief under section 6015(f) where no deficiency has been asserted with respect to petitioner’s taxable year 1998 or her taxable year 2002. Bill- ings v. Commissioner, 127 T.C. 7 (2006). 2Assuming arguendo (1) that we had the authority in the instant case to determine whether the levy issued to Mr. Arcodia was valid and (2) that we were to determine that that levy was invalid, the fact nonetheless remains that there was no liability for tax for petitioner’s taxable year 1998 or her taxable year 2002 that remained unpaid on or after Dec. 20, 2006, the date of the enactment of the Act. That would be true even if petitioner were entitled to a refund of the amount that Mr. Arcodia paid on Apr. 27, 2006, with respect to the tax liability for each of those years.Page: Previous 1 2 3 4 5 6 7 8 NextLast modified: November 10, 2007