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The conference agreement follows the Senate
amendment with respect to deficiencies of a taxpayer
who is no longer married to, is legally separated from,
or has been living apart for at least 12 months from
the person with whom the taxpayer originally filed the
joint return. The conference agreement also includes
the provision in the House bill expanding the
circumstances in which innocent spouse relief is
available. Taxpayers, whether or not eligible to make
the separate liability election, may be granted
innocent spouse relief where appropriate. In addition,
the conference agreement authorizes the Secretary to
provide equitable relief in appropriate situations.
The conference agreement follows the House bill and the
Senate amendment in establishing jurisdiction in the
Tax Court over disputes arising in this area. [H.
Conf. Rept. 105-599, supra at 251, 1998-3 C.B. at 1005;
emphasis added.]
The language in the conference report indicates that the
reference to disputes arising in “this area” was intended to
encompass claims for relief arising under section 6015(b), (c),
and (f). The reference to our jurisdiction comes directly after
the conference report discussed the Senate amendment (relating to
section 6015(c)), the House bill (relating to section 6015(b)),
and the conference agreement’s new provision authorizing
equitable relief in appropriate situations (relating to section
6015(f)). The conference report then states that it follows the
House bill and Senate amendment in establishing jurisdiction in
this Court over disputes arising in “this area”.8 Additionally,
8The General Explanation of Tax Legislation Enacted in 1998
prepared by the Staff of the Joint Committee on Taxation states:
The provision establishes three procedures for
limiting the portion of a joint and several liability
(continued...)
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