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tax liabilities for those years were fully paid before
December 20, 2006.
On May 14, 2007, the Court held a hearing on respondent’s
motion at its trial session in Miami, Florida. Petitioner’s and
respondent’s counsel appeared and were heard. At the hearing, we
directed petitioner to submit a response to respondent’s
supplement and offered respondent the opportunity to reply to
petitioner’s response.
On June 15, 2007, petitioner’s response to respondent’s
supplement was filed. On July 12, 2007, respondent replied.
Discussion
I. Section 6015(e)
Section 6015(e) generally allows a spouse who has requested
relief from joint and several liability to contest the
Commissioner’s denial of relief under section 6015 by filing a
timely petition in this Court. Before the enactment of TRHCA
section 408, the Court had jurisdiction over such cases only if
the Commissioner had asserted a deficiency against the taxpayer.
See Billings v. Commissioner, 127 T.C. 7 (2006). TRHCA section
408 amended section 6015(e) to confer jurisdiction on the Court
over stand-alone requests for equitable relief under section
6015(f), but only with respect to tax liabilities arising or
remaining unpaid on or after December 20, 2006.
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Last modified: March 27, 2008