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all subsections of section 6015); Butler v. Commissioner, 114
T.C. at 290 (same); Woodral v. Commissioner, 112 T.C. 19, 22-23
(1999) (interpreting reference to “this section” in section
6404(g) to encompass all subsections of section 6404).
Accordingly, we conclude that, in enacting section 6015, Congress
did not intend to limit our authority to review claims for relief
from joint and several liability to deficiency situations.
B. Amendment of Section 6015(e)
Subsequent to our opinions in Fernandez v. Commissioner,
supra, and Butler v. Commissioner, supra, Congress amended
section 6015(e) effective on December 21, 2000. Consolidated
Appropriations Act, 2001 (Consolidated Appropriations Act, 2001),
Pub. L. 106-554, app. G, sec. 313, 114 Stat. 2763, 2763A-641-643.
As a result, section 6015(e) currently provides, in pertinent
part:
SEC. 6015(e). Petition for Review by Tax Court.--
(1) In general.–-In the case of an individual
against whom a deficiency has been asserted and who
elects to have subsection (b) or (c) apply--
(A) In general.–-In addition to any
other remedy provided by law, the individual
may petition the Tax Court (and the Tax Court
shall have jurisdiction) to determine the
appropriate relief available to the
individual under this section * * *
[Emphasis added.]
The petition in the instant case was filed after the effective
date of this provision. The issue we must decide is whether the
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