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534, 542-543 (1940); Hospital Corp. of Am. v. Commissioner, 107
T.C. 116, 128 (1996). Phrases must be construed in light of the
overall purpose and structure of the whole statutory scheme.
Dole v. United Steelworkers of Am., 494 U.S. 26, 35 (1990).
The plain meaning of statutory language ordinarily is
conclusive. United States v. Ron Pair Enters., Inc., 489 U.S.
235, 241-242 (1989); Hospital Corp. of Am. v. Commissioner,
supra. If the language of a statute is clear, we look no further
than that language in determining the statute's meaning. See
Sullivan v. Stroop, 496 U.S. 478, 482 (1990); United States v.
Ron Pair Enters., Inc., supra at 241. A court looks to
legislative history only if the statute is unclear. Blum v.
Stenson, 465 U.S. 886, 896 (1984); United States v. Lewis, 67
F.3d 225, 228-229 (9th Cir. 1995).
I. Jurisdiction Under Section 6404(g)
The Tax Court is a court of limited jurisdiction and may
exercise jurisdiction only to the extent authorized by Congress.
Naftel v. Commissioner, 85 T.C. 527, 529 (1985). The question of
the Court's jurisdiction is fundamental and must be addressed
when raised by a party. Id. at 530.
Section 6404(g) provides in pertinent part:
The Tax Court shall have jurisdiction over any action
brought by a taxpayer who meets the requirements
referred to in section 7430(c)(4)(A)(ii) to determine
whether the Secretary's failure to abate interest under
this section was an abuse of discretion, and may order
an abatement, if such action is brought within 180 days
after the date of the mailing of the Secretary's final
determination not to abate such interest. [Emphasis
added.]
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