Diane Fernandez - Page 9




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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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