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Bauxites de Guinee, 456 U.S. 694, 702 (1982); Williams v. Secy.
of Navy, 787 F.2d 552, 557 (Fed. Cir. 1986); Brown v.
Commissioner, 78 T.C. 215, 217-218 (1982). The Court may not
acquire jurisdiction upon the consent of the parties, California
v. LaRue, 409 U.S. 109, 112 n.3 (1972), or through some equitable
principle such as estoppel, Am. Fire & Cas. Co. v. Finn, 341 U.S.
6, 17-18 (1951); Flight Attendants Against UAL Offset v.
Commissioner, 165 F.3d 572, 578 (7th Cir. 1999). The Court’s
decision as to an issue over which it does not have jurisdiction
is void, Ruhrgas AG v. Marathon Oil Co., 526 U.S. 574, 583
(1999); Steel Co. v. Citizens for Better Envt., 523 U.S. 83,
101-102 (1998), and may be challenged at any time, including upon
appeal, Ins. Corp. of Ir., Ltd. v. Compagnie des Bauxites de
Guinee, supra at 702.
Congress added section 6015 to the Code as part of the
Internal Revenue Service Restructuring and Reform Act of 1998
(RRA 1998), Pub. L. 105-206, sec. 3201, 112 Stat. 685, 734, in
order to expand the relief available to taxpayers from joint and
several liability (joint liability) on a joint return. S. Rept.
105-174, at 55 (1998), 1998-3 C.B. 591; H. Rept. 105-364 (Part I)
at 61 (1997), 1998-3 C.B. 433. Each spouse who files a joint
Federal income tax return is generally responsible for the
accuracy of that return and is subject to joint liability for tax
deficiencies stemming therefrom. Sec. 6013(d)(3). Such is the
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