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those types of relief is limited to the jurisdictional powers
granted to the Court in the House bill and in the Senate
amendment. Because neither of those documents empowered the
Court to decide a matter stemming from a petition requesting
equitable relief under section 6015(f), I consider it only
natural to conclude that section 6015 also does not contain that
jurisdiction in a nondeficiency case. To be sure, the fact that
the conferees’ equitable relief provision was not a part of
either the House bill or the Senate amendment negates the
majority’s conclusion that the Court’s jurisdiction to review a
claim for equitable relief under section 6015(f) is found in both
the House bill and in the Senate amendment.
I find additional support for my conclusion in the general
explanation of the RRA 1998 as set forth in the Staff of Joint
Comm. on Taxation, General Explanation of Tax Legislation Enacted
in 1998 (J. Comm. Print 1998), 1998-4 C.B. 543. Although that
general explanation is not part of the RRA 1998’s legislative
history, see Estate of Hutchinson v. Commissioner, 765 F.2d 665,
669-670 (7th Cir. 1985), affg. T.C. Memo. 1984-55; Condor Intl.,
Inc. v. Commissioner, 98 T.C. 203, 227 (1992), I respect it as a
document that was prepared in connection with the legislative
process by individuals who were intimately involved in that
process. Estate of Wallace v. Commissioner, 965 F.2d 1038,
1050-1051 n.15 (11th Cir. 1992), affg. 95 T.C. 525 (1990). My
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