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Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3201,
112 Stat. 685, 734. The provision provides relief from joint and
several liability for certain taxpayers who file a joint Federal
income tax return. In general terms, there are three avenues of
relief under section 6015: Section 6015(b) may provide relief
with respect to certain erroneous items on the return, section
6015(c) may provide for a separation of liability for separated
taxpayers, and section 6015(f) may provide equitable relief for
taxpayers who otherwise do not qualify for relief under either of
the other two provisions. As a general rule, taxpayers who
qualify for relief under section 6015(b) or (f)--but not section
6015(c)--are entitled to a refund or credit attributable to the
application of section 6015. Sec. 6015(g)(1), (3).
After a taxpayer requests relief under section 6015, the
taxpayer may petition this Court for a review of respondent’s
subsequent determination. Sec. 6015(e)(1)(A). Our jurisdiction
in cases brought under section 6015(e)(1) encompasses a review of
respondent’s determination with respect to all relief afforded by
section 6015. Fernandez v. Commissioner, 114 T.C. 324, 331
(2000). Thus, we have jurisdiction to review respondent’s
determination that no refund is due petitioner pursuant to
section 6015(g)(3). However, we note that we have jurisdiction
with respect to only a portion of the tax liability at issue in
this case. Overpayments which are credited to another year’s tax
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