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It is axiomatic that we are a Court of limited jurisdiction
and may exercise our power only to the extent authorized by
Congress. Gati v. Commissioner, 113 T.C. 132, 133 (1999); Naftel
v. Commissioner, 85 T.C. 527, 529 (1985). In her “stand alone”
petition, petitioner invoked our jurisdiction pursuant to section
6015(e) to review the Commissioner’s denial of her request for
relief from joint and several liability. Section 6015(e)(1)
provides in pertinent part:
SEC. 6015(e). Petition for Review by Tax Court.--
(1) In general.--In the case of an individual
against whom a deficiency has been asserted and who
elects to have subsection (b) or (c) apply--
(A) In general.--In addition to any other
remedy provided by law, the individual may
petition the Tax Court (and the Tax Court shall
have jurisdiction) to determine the appropriate
relief available to the individual under this
section if such petition is filed--* * * [Emphasis
added.]
We agree with respondent that the plain language of section
6015(e)(1) limits our jurisdiction to review the Commissioner’s
denial of the specific relief contemplated under section 6015.8
See Ewing v. Commissioner, supra at 499; Butler v. Commissioner,
114 T.C. 276, 290 (2000); Brown v. Commissioner, T.C. Memo. 2002-
8“The plain meaning of legislation should be conclusive,
except in the ‘rare cases [in which] the literal application of a
statute will produce a result demonstrably at odds with the
intentions of its drafters.’” United States v. Ron Pair Enters.,
Inc., 489 U.S. 235, 242 (1989) (quoting Griffin v. Oceanic
Contractors, Inc., 458 U.S. 564, 571 (1982)).
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