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1992, 1993, 1994, 1995, or 1996 (the years in issue). Petitioner
petitioned this Court under section 6015(e)(1) and contends she
is eligible for relief under section 6015(f). Petitioner’s
former husband, Stanley Murray (intervenor), intervened and
supports her claim.2 See Rule 325(b). We hold that petitioner
is entitled to relief under section 6015(f) for the years in
issue.3
Based on Billings v. Commissioner, 127 T.C. 7 (2006), and
Commissioner v. Ewing, 439 F.3d 1009 (9th Cir. 2006), revg. 118
T.C. 494 (2002) and vacating 122 T.C. 32 (2004), we dismissed
this case for lack of jurisdiction by order dated October 2,
2006. See also Bartman v. Commissioner, 446 F.3d 785 (8th Cir.
2006), affg. in part and vacating in part T.C. Memo. 2004-93.
However, Congress subsequently 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. Tax Relief and Health Care Act of 2006, Pub.
L. 109-432, div. C, sec. 408, 120 Stat. 3061. The parties
1(...continued)
Court Rules of Practice and Procedure.
2 We previously held that Mr. Murray may intervene to
support petitioner’s claim for relief. Van Arsdalen v.
Commissioner, 123 T.C. 135 (2004).
3 Respondent contends that we may consider only the
administrative record in deciding this case. See discussion
below at par. D, p. 20.
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