Gwendolyn A. Ewing - Page 15




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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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