Roxanne M. Toppi - Page 7

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          that we lack jurisdiction over the instant case.3  Accordingly,             
          we do not reach the issue of whether petitioner is entitled to              
          relief pursuant to section 6015(f).                                         
               To reflect the foregoing,                                              

                                              An appropriate order of                 
                                        dismissal for lack of jurisdiction            
                                        will be entered.                              






















               3We note that Senators Feinstein and Kyl have recently                 
          introduced S. 3523, 109th Cong., 2d Sess., sec. 1 (2006), that              
          would, if enacted, clarify that the Court has jurisdiction under            
          sec. 6015(e) to review all claims for relief under sec. 6015(f).            
          See also 152 Cong. Rec. S5962 (daily ed. June 15, 2006) (Senator            
          Feinstein stating: “this bill clarifies the statute’s original              
          intent”).                                                                   




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