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PARR, J., dissenting: I have joined with Judge Colvin in his
dissenting opinion, because I believe the language of section
6015(c)(3)(C) is ambiguous and that we should consult legislative
history for guidance in resolving that ambiguity. I write
separately only to express my concern about the Court's application
of section 6013(e) case law to the case at hand.
Section 6015 is a remedial statute, therefore, its provisions
should be construed and applied liberally in favor of those whom
the statute was designed to benefit. Cf. Helvering v. Bliss, 293
U.S. 144, 150-151 (1934); Allen v. Commissioner, 514 F.2d 908, 915
(5th Cir. 1975). Moreover, it is apparent that Congress intended
section 6015 to provide broader relief than that provided by
section 6013(e).
In its discussion of section 6015(f), the majority has found--
and I agree--that, considering the facts and circumstances of this
case, it is not inequitable to hold petitioner liable for the
deficiency. Since equitable consideration is also a requirement
for relief under section 6015(b)(1)(D), the majority's discussion
of section 6015(b)(1)(C) is unnecessary. The word "understatement"
used in section 6015(b)(1)(C) is different from the word "item"
construed in the discussion of section 6015(c)(3)(C). Yet the
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