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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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