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petitioner's affirmative defense that she is entitled to innocent
spouse treatment is governed by our general jurisdiction to
consider any issue which affects the deficiency before us. See
sec. 6213. Petitioner's innocent spouse claim is one such issue.
Respondent argues that section 6015(e) precludes judicial
review of claims made pursuant to subsection (f) and limits
judicial review only to claims made pursuant to subsections (b)
and (c). Respondent contends, inter alia, that the references in
section 6015(e)(3) and (4) to subsections (b) and (c), coupled
with silence with regard to subsection (f), evidence an intent by
Congress to segregate proceedings involving subsection (f) from
proceedings involving subsections (b) and (c). Respondent
contends that the foregoing statutory scheme, as well as the
express language of the statute, evidence a congressional intent
to preclude judicial review of determinations made by the
Commissioner pursuant to section 6015(f). Alternatively,
respondent argues that the Commissioner's determinations pursuant
to subsection (f) are "committed to agency discretion" by law.
This Court has stated that there exists a strong presumption
that the actions of an administrative agency are subject to
judicial review. See, e.g., Mailman v. Commissioner, 91 T.C.
1079, 1082 (1988); Estate of Gardner v. Commissioner, 82 T.C.
989, 994 (1984). Agency action is exempt from judicial review
only: (1) Where the governing statutes expressly preclude such
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