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opportunity to become a party to a proceeding under
either such subsection.
We have been asked, in this “stand alone” petition filed
pursuant to section 6015(e)(1)(A), to decide whether we have
authority to review a denial of relief under section 6015(f).
Since our jurisdiction in this case is dependent upon section
6015(e)(1)(A), we look to the language of section 6015 to
determine whether we have authority to review a denial of relief
under section 6015(f). In Butler v. Commissioner, 114 T.C. ___
(2000), respondent argued that section 6015(e) precluded judicial
review of claims made pursuant to section 6015(f). We opined in
Butler that “We find nothing in section 6015(e) that precludes
our review of respondent’s denial of equitable relief to
petitioner”.
In this case, respondent asserts that, since section
6015(e)(1) provides “in the case of an individual who elects to
have subsection (b) or (c) apply”, the language of the statute
limits our jurisdiction to the review of an election made under
subsection (b) or (c). Therefore, respondent contends, we do not
have jurisdiction to review relief under subsection (f). We do
not agree, as explained more fully below.
When we interpret section 6015(e) to determine the scope of
our jurisdiction, our purpose is to give effect to Congress’
intent. To accomplish this, we must begin with the statutory
language, which is the most persuasive evidence of the statutory
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