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respect for the joint committee’s understanding of a statute is
greatest where, as here, the understanding is fully supported by
corroboration in the legislative history. Estate of Hutchinson
v. Commissioner, supra at 669-670; Zinniel v. Commissioner,
89 T.C. 357, 367 (1987), affd. 883 F.2d 1350 (7th Cir. 1989).
Cf. Allen v. Commissioner, supra at 15 (joint committee’s
explanation of certain provisions of the alternative minimum tax
regime were entitled to little respect given the lack of
corroboration in the legislative history). Consistent with my
understanding of the jurisdictional issue, the joint committee
recognized in its report that section 6015 provides taxpayers
with three possible types of relief from joint liability; i.e.,
modified innocent spouse relief, the separate liability election,
and equitable relief. Moreover, like me, the joint committee
understood that this Court is empowered to decide in a stand-
alone petition as an independent action only the first two types
of relief. In order to decide a claim to equitable relief,
therefore, the joint committee’s explanation indicates that the
Court must otherwise have jurisdiction over the underlying case
by virtue of another grant of authority; e.g., by way of the
petition in Butler v. Commissioner, 114 T.C. at 288 (2000), to
redetermine a deficiency under section 6213(a), or by way of the
petition in Fernandez v. Commissioner, 114 T.C. 324 (2000), to
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