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provision, vesting the Court with jurisdiction to review
respondent’s administrative determination to grant Ms. Maier
relief from joint and several liability.
Petitioner contends that, absent review by the Court, he
will be left without a judicial remedy. Whether petitioner truly
lacks a judicial remedy or not, it is well settled that the Court
may not rely on equitable considerations to expand its
jurisdiction beyond the parameters established by Congress. See
Commissioner v. McCoy, 484 U.S. 3, 7 (1987) (holding per curiam
that the Tax Court is "a court of limited jurisdiction and lacks
general equitable powers"); Healy v. Commissioner, 351 F.2d 602,
603 (9th Cir. 1965) (holding in the context of a late filing that
"no matter how allegedly inequitable the situation" the Tax Court
does not have the authority to excuse a taxpayer from
jurisdiction requirements in the statute); Axe v. Commissioner,
58 T.C. 256, 259 (1972). To the extent that petitioner believes
that he has suffered an injustice due to a flaw in the
controlling statutory provisions, his recourse may be to seek a
legislative remedy.
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