§11081

11081, 131 Stat. at 2092. The deficiency at issue here stems from an increase in tax due to excess APTC paid on petitioners’ behalves throughout 2018 before the ACA amendments discussed in Texas took effect. Therefore, the reasoning of the U.S. Court of Appeals for the Fifth Circuit in Texas does not apply.

*11] maintain minimum essential coverage. See McGuire, 149 T.C. at 258; Millen v. Commissioner, T.C. Memo. 2019-60, at *4 & n.2, aff’d per order, 124 A.F.T.R.2d 2019-6733 (6th Cir. 2019); see also Tax Cuts and Jobs Act of 2017, Pub. L. No. 115-97, § 11081, 131 Stat. 2054, 2092 (amending section 5000A such that taxpayers are generally not liable for the shared responsibility payment for months beginning after December 31, 2018). As we have explained, Congress specifically provided by statute that

11081, 131 Stat. at 2092. - 5 - [*5] rupted her inquiry by insisting that he had timely submitted an earlier version ofhis 2015 return. Relying on his account transcript, the SO stated that the IRS had no record ofan earlier filed return. In any event, she explained that the IA had been terminated, not for petitioner's failure to file a 2015