- 23 - The Conference report states that it follows the "House bill and the Senate amendment in establishing jurisdiction in the Tax Court over disputes arising in this area." H. Conf. Rept. 105- 599, at 251 (1998). In short, there is no language in either the statute or the legislative history that precludes our review of the Commissioner's denial of equitable relief pursuant to section 6015(f) where the taxpayer has made the requisite election for relief pursuant to section 6015(b) or (c). But see In re Mira, 245 Bankr. 788 (Bankr. M.D. Pa. 1999). We also disagree with respondent's argument that the Commissioner's authority to grant equitable relief pursuant to section 6015(f) is "committed to agency discretion by law." The "committed to agency discretion" exception to the general rule of judicial review is a very narrow one. (Estate of Gardner v. Commissioner, supra at 995, citing Citizens to Preserve Overton Park, Inc. v. Volpe, 401 U.S. 402, 410 (1971)). The exception applies only in those rare instances in which a statute is drawn in terms so broad that there is no law to apply. See id. Whether there is law to apply turns on pragmatic considerations as to whether an agency determination is the proper subject of judicial review. See id. In Mailman v. Commissioner, supra at 1082-1083, we stated:Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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