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ambiguity. See discussion infra. The plain meaning of the
statutory text at issue is not ambiguous.
My disagreement with the majority opinion focuses primarily
on the opinion’s misapplication of section 6015(e), the
provisions of which I consider to be a clear statutory mandate
from Congress. Section 6015(e) empowers the Court to review a
taxpayer’s stand-alone petition challenging the Commissioner’s
determination as to the taxpayer’s administrative claim for
relief from joint liability under section 6015. Section 6015(e)
provides in relevant 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 if such
petition is filed * * * [timely]
I parse the quoted text of section 6015(e) into the separate
statements which Congress has carefully chosen to prescribe under
the heading “Petition for Review by Tax Court”. The plain
reading of each of these statements establishes the prerequisite
to the Court’s obtaining jurisdiction in the case of a stand-
alone petition. The majority reads these statements differently,
in fact, declining to apply many of the statements in order to
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