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also has jurisdiction to consider appropriate spousal defenses in
the context of a petition for review of a lien or levy action.
Sec. 6330(c)(2)(A)(i) and (d)(1)(A); sec. 301.6330-1(e)(2),
Proced. & Admin. Regs.
Unlike section 6015, section 66 does not specifically and
separately grant this Court jurisdiction over the Commissioner’s
denial of equitable relief under section 66(c). In Fernandez v.
Commissioner, 114 T.C. 324 (2000), we considered a petition filed
under the “stand alone” provisions of section 6015(e). We
pointed out in Fernandez that our jurisdiction depended upon the
specific provisions of section 6015(e)(1)(A). Id. at 329. In
fact, section 6015(e) sets forth specific and separate provisions
for filing a petition for review of the appropriate relief
available with respect to a claim for relief from joint and
several liability. While section 66(c) permits a spouse who does
not file joint returns to seek relief from the effects of
community income, said section does not contain a parallel
provision to section 6015(e) providing for review by the Tax
Court. Without such a parallel provision the conclusion is
evident, that we do not have jurisdiction to consider a “stand
alone” petition under section 66. As noted supra note 5, section
66(c) was amended at the same time as the enactment of section
6015. There is nothing in the statute or legislative history
from which we could conclude that Congress intended to provide
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