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for Tax Court review in situations involving both deficiencies
and underpayments of tax shown on the return. Id. at 56, 1998-3
C.B. at 592. The Senate amendment also added an “Equitable
Relief” provision similar to what is now contained in section
6015(f), providing equitable relief “for any unpaid tax or any
deficiency”. 144 Cong. Rec. S4577 (daily ed. May 8, 1998). The
Senate amendment also provided for Tax Court jurisdiction “In the
case of an individual who elects to have this section [section
6015] apply”. Id. The conference agreement did not include the
portion of the Senate amendment applying the separate liability
election in situations where the tax shown on the return was not
paid with the return. However, the conference agreement added
section 6015(f) which, like the Senate amendment, allows
equitable relief for unpaid tax shown on the return. H. Conf.
Rept. 105-599, at 254 (1998), 1998-3 C.B. 755, 1008. The
conference agreement followed the Senate amendment in
establishing Tax Court jurisdiction in this area. Id.
The following language contained in the conference report
supports our view that, in enacting section 6015, Congress
intended for this Court to have jurisdiction over situations
involving any claim for relief from joint and several liability,
including nondeficiency situations where an individual is seeking
relief only for an underpayment of tax shown on a joint return:
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