- 42 -
Washington v. Commissioner, supra at 155-156; see also Tcherepnin
v. Knight, 389 U.S. 332, 336 (1967) (remedial legislation should
be construed broadly to effectuate its purposes); Piedmont & N.
Ry. Co. v. ICC, 286 U.S. 299, 311 (1932) (remedial legislation
should be given a liberal interpretation).
B. “Application of this section”
Section 6015(g)(1) provides that “credit or refund shall be
allowed or made to the extent attributable to the application of
this section.” In Fernandez v. Commissioner, supra at 331, in
determining whether the Court has jurisdiction to review a
request for relief under section 6015(f), we stated: “It is our
view that Congress intended the term ‘under this section’ to
include all subsections of 6015 in their entirety.” See Butler
v. Commissioner, 114 T.C. 276, 290 (2000); see also Woodral v.
Commissioner, 112 T.C. 19, 22-23 (1999). Accordingly, the Court
must apply all subsections of section 6015, including subsection
(a), to determine the amount of a taxpayer’s refund pursuant to
subsection (g).
C. Section 6015(a)
1. The Flush Language
The flush language at the end of section 6015(a) provides:
“Any determination under this section shall be made without
regard to community property laws.” The majority invents a
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