Gwendolyn A. Ewing - Page 20

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               7.   Conclusion                                                        
               Part of our interpretative responsibility here is to give              
          proper effect to both section 6015(e) and (f).  Courts attempt to           
          read statutory provisions harmoniously, so as to give proper                
          effect to all of the words of the statute.  See FDA v. Brown &              
          Williamson Tobacco Corp., 529 U.S. 120, 133 (2000) (citing FTC v.           
          Mandel Bros., Inc., 359 U.S. 385, 389 (1959)); Bend v. Hoyt, 38             
          U.S. 263, 272 (1839).  We have done so here.  We read these                 
          provisions to give effect to the other.  Our de novo review of              
          the Commissioner’s determinations under section 6015(f) gives               
          effect to the congressional mandate that we determine whether a             
          taxpayer is entitled to relief under section 6015.  The measure             
          of deference provided by the abuse of discretion standard is a              
          proper response to the fact that section 6015(f) authorizes the             
          Secretary to provide procedures under which, based on all the               
          facts and circumstances, the Secretary may relieve a taxpayer               
          from joint liability.  That approach (de novo review, applying an           
          abuse of discretion standard) properly implements the statutory             
          provisions at issue here, and has a long history in numerous                
          other areas of Tax Court jurisprudence.  See supra pp. 14-16.               
               We conclude that our determination whether petitioner is               
          entitled to equitable relief under section 6015(f) is made in a             
          trial de novo and is not limited to matter contained in                     








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