§313

2763A-643, Congress legislatively overruled Henry Randolph Consulting v.

See Act § 313(b), 136 Stat. at 5349. On July 27, 2023, P filed a Motion for Partial Sum- mary Judgment. He contends that I.R.C. § 6501(l)(4) ap- plies retroactively, and that the notice of deficiency for 2004–2008 was untimely because it was issued more than six years after his 2004–2008 tax returns were filed. Held: I.R.C. § 6501(l)(4) is applicable only with re- spect to tax returns filed on or after December 29, 2022. Because P’s returns were filed before December 29, 2022, I.R.C. § 6501(l)(4

490. In that Act, Congress eliminated the exemption from Federal income tax for domestic building and loan associations and instead enacted generous rules for calculating deductions for additions to bad debt reserves. Revenue Act of 1951, ch. 521, sec. 313(e), 65 Stat. 490-491. The legislative - 16 - history for the 1951 Act ind

Section 1402(a)(13) was originally enacted in 1977 (as section 1402(a)(12)), before limited liability companies were widely used or generally treated as partnerships for Federal tax purposes." Social Security Amendments of 1977, Pub. L. No. 95-216, sec. 313(b), 91 Stat. at 1536; Renkemeyer, Campbell, & Weaver, LLP v. Commissioner (Renkemeyer), 136 T.C. 137, 148 (2011). As the Court noted in Renkemeyer, no statutory or regulatory authority defines "limited partner" for the purposes ofsection 1402

Section 1402(a)(13) was originally enacted in 1977 (as section 1402(a)(12)), before limited liability companies were widely used or generally treated as partnerships for Federal tax purposes." Social Security Amendments of 1977, Pub. L. No. 95-216, sec. 313(b), 91 Stat. at 1536; Renkemeyer, Campbell, & Weaver, LLP v. Commissioner (Renkemeyer), 136 T.C. 137, 148 (2011). As the Court noted in Renkemeyer, no statutory or regulatory authority defines "limited partner" for the purposes ofsection 1402

Section 1402(a)(13) was originally enacted in 1977 (as section 1402(a)(12)), before limited liability companies were widely used or generally treated as partnerships for Federal tax purposes." Social Security Amendments of 1977, Pub. L. No. 95-216, sec. 313(b), 91 Stat. at 1536; Renkemeyer, Campbell, & Weaver, LLP v. Commissioner (Renkemeyer), 136 T.C. 137, 148 (2011). As the Court noted in Renkemeyer, no statutory or regulatory authority defines "limited partner" for the purposes ofsection 1402

313(a)(1), 114 Stat. at 2763A-640 (2000), Congress clarified section 6015(c) by allowing taxpayers to make the election "at any time after a deficiency for such year is asserted", subject to the two-year limitation noted above. The conference report accompanying the change indicated - 20 - [*20] that a "deficiency is considered to have been a

313(b), 91 Stat. 1536. The relevant legislative history provides insight with respect to Congress' intent: Under present law each partner's share of -partnership income is includable in his net earnings from self- employment for social security purposes, irrespective of the nature of his membership in the partnership. The bill would exclude fr

313(b), 91 Stat. 1536. The relevant legislative history provides insight with respect to Congress' intent: Under present law each partner's share of -partnership income is includable in his net earnings from self- employment for social security purposes, irrespective of the nature of his membership in the partnership. The bill would exclude fr

ther than section 6512(b), 7121, or 7122), credit or refund shall be allowed or made to the extent attributable to the application of subsection (b) or (f). The technical corrections in the Community Renewal Tax Relief Act of 2000, Pub. L. 106-554, sec. 313, 114 Stat. 2763A-640, 2763A- 641, amended subsection (e)(3) by redesignating subsection (g) as (h) and adding new subsection (g)(1), which provides: SEC. 6015(g). Credits and Refunds.-- (1) In general.--Except as provided in paragraphs (2) an

2763A-641 (2000). Essentially the same phrase was added to sec. 6015(c)(3)(B), effective on the same date, by the 2001 Consolidated Appropriations Act. Id. After that amendment, sec. (continued...) - 26 - Court’s jurisdiction to review claims for relief under section 6015 was not limited to claims for relief from taxes that may

the same taxable year has become final, such decision shall be conclusive except with respect to the qualification of the individual for relief which was not an issue in such proceeding. The exception contained in the preceding sentence shall not 3 Sec. 313(a)(2)(A) of the Consolidated Appropriations Act of 2001, Pub. L. 106-554, 114 Stat. 2763A-640 (2000), redesignated former subsec. (g) as subsec. (h) and inserted after subsec. (f) a new subsec. (g) (as quoted above). For a more detailed disc

the same taxable year has become final, such decision shall be conclusive except with respect to the qualification of the individual for relief which was not an issue in such proceeding. The exception contained in the preceding sentence shall not 3 Sec. 313(a)(2)(A) of the Consolidated Appropriations Act of 2001, Pub. L. 106-554, 114 Stat. 2763A-640 (2000), redesignated former subsec. (g) as subsec. (h) and inserted after subsec. (f) a new subsec. (g) (as quoted above). For a more detailed disc

2763, 2763A-641-643. As a result, section 6015(e) currently provides, in pertinent part: SEC. 6015(e). Petition for Review by Tax Court.-- (1) In general.–-In the case of an individual against whom a deficiency has been asserted and who elects to have subsection (b) or (c) apply-- (A) In general.–-In addition to any other remedy

313(a)(2)(A) of the Consolidated Appropriations Act of 2001, Pub. L. 106-554, 114 Stat. 2763, redesignated former subsec. (g) as subsec. (h) and inserted after subsec. (f) a new subsec. (g) which provides in pertinent part: SEC. 6015(g) Credits And Refunds.-- * * * * * * * (continued...) - 11 - must respect the State court’s final judgment of

2763A-641. - 10 - Because the 1995 tax liability was paid in full, no relief is available to petitioner under section 6015(c). Petitioner admits to knowing about the pension income, unemployment compensation, and State income tax refund and is therefore not eligible for relief from joint liability under section 6015(b) with res

subsection (g). See Consolidated Appropriations Act, 2001, Pub. L. 106-554, sec. 1(a)(7), 114 Stat. 2763. (Hereinafter referred to as Consolidated Appropriations Act, 2001). This amendment to RRA 1998 became effective on December 21, 2000. See id., sec. 313(f), 114 stat. 2763A-643. In discussing the proper time to elect relief under section 6015, the conference report that accompanied the Consolidated Appropriations Act, 2001, states as follows: Congress did not intend that taxpayers be prohibi