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Fernandez v. Commissioner, 114 T.C. 324 (2000); Butler v.
Commissioner, 114 T.C. 276 (2000).
The question that the Court addressed sua sponte in Ewing I
was whether the amendment of section 6015(e)(1) deprived the
Court of its jurisdiction to review a claim for relief under
section 6015(f) from all or a portion of any unpaid tax in a
stand-alone section 6015(f) “nondeficiency” case. Ewing v.
Commissioner, supra at 503. In resolving that question, the
Court analyzed section 6015(e)(1) both before and after its
amendment by the 2001 Consolidated Appropriations Act.6 Id. at
502-507. In analyzing that section after its amendment, the
Court stated:
6In analyzing sec. 6015(e)(1) as amended by the 2001
Consolidated Appropriations Act, the Court relied on the
following rules of statutory construction:
In interpreting section 6015(e), our purpose is to
give effect to Congress’s intent. * * * We begin with
the statutory language, and we interpret that language
with reference to the legislative history primarily to
learn the purpose of the statute and to resolve any
ambiguity in the words contained in the language. * * *
Usually, the plain meaning of the statutory language is
conclusive. * * * If the statute is ambiguous or
silent, we may look to the statute’s legislative
history to determine Congressional intent. * * *
Finally, because the changes to the relief from joint
and several liability rules “were designed to correct
perceived deficiencies and inequities in the prior
version” of the rules, this curative legislation should
be construed liberally to effectuate its remedial
purpose. * * *
Ewing v. Commissioner, 118 T.C. at 503.
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