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amendment to section 6015(e) by the Consolidated Appropriations
Act, 2001, presents a new requirement that a deficiency must be
asserted before this Court has jurisdiction to review
respondent’s denial of equitable relief pursuant to section
6015(f) in a “stand alone” proceeding.
In interpreting section 6015(e), our purpose is to give
effect to Congress’s intent. Fernandez v. Commissioner, supra at
329. We begin with the statutory language, and we interpret that
language with reference to the legislative history primarily to
learn the purpose of the statute and to resolve any ambiguity in
the words contained in the language. Allen v. Commissioner, 118
T.C. 1, 7 (2002) (and cases cited therein). Usually, the plain
meaning of the statutory language is conclusive. United States
v. Ron Pair Enters., Inc., 489 U.S. 235, 242 (1989); Woodral v.
Commissioner, supra at 23. If the statute is ambiguous or
silent, we may look to the statute’s legislative history to
determine congressional intent. Burlington N. R.R. v. Okla. Tax
Commn., 481 U.S. 454, 461 (1987); Fernandez v. Commissioner,
supra at 329-330. Finally, because the changes to the relief
from joint and several liability rules “were designed to correct
perceived deficiencies and inequities in the prior version” of
the rules, this curative legislation should be construed
liberally to effectuate its remedial purpose. Flores v. United
States, 51 Fed. Cl. 49, 53 (2001) (citing Tcherepnin v. Knight,
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