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purpose. See United States v. American Trucking Associations,
Inc., 310 U.S. 534, 542-543 (1940). Usually, the plain meaning
of the statutory language is conclusive. See United States v.
Ron Pair Enters., Inc., 489 U.S. 235, 242 (1989); Woodral v.
Commissioner, 112 T.C. 19, 23 (1999). If a statute is silent or
ambiguous, we may look to the statute’s legislative history in an
attempt to determine congressional intent. See Burlington N.
R.R. v. Oklahoma Tax Commn., 481 U.S. 454, 461 (1987); Griswold
v. United States, 59 F.3d 1571, 1575-1576 (11th Cir. 1995). When
a statute appears to be clear on its face, there must be
unequivocal evidence of legislative purpose before interpreting
the statute so as to override the plain meaning of the words used
therein. See Huntsberry v. Commissioner, 83 T.C. 742, 747-748
(1984); see also Pallottini v. Commissioner, 90 T.C. 498, 503
(1988), and the cases cited therein.
We first look to the prefatory language contained in section
6015(e)(1) which states: “in the case of an individual who elects
to have subsection (b) or (c) apply”. We conclude that this
language does not contain words of limitation that confine our
jurisdiction to review of an election under subsections (b)
and/or (c), as respondent contends. Rather, we understand this
language to encompass the procedural requirement applicable to
all joint filers seeking innocent spouse relief and, therefore,
states the prerequisite to seeking our review of such relief.
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