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accordingly, we hold that he is not entitled to relief under
section 6015 for the taxable year in issue.
C. Ms. Lewallen
Ms. Lewallen earned approximately one-third of the income
giving rise to the understatement of tax. Mr. Munsinger earned
the bulk of it. In both the petition and at trial, Ms. Lewallen
requested that she not be held liable for more than half of the
deficiency resulting from the underreporting of wages. However,
despite the understandable nature of her request, the Court is a
court of limited jurisdiction, and we are not at liberty to make
decisions based solely in equity. See Commissioner v. McCoy, 484
U.S. 3, 7 (1987); Woods v. Commissioner, 92 T.C. 776, 784-787
(1989); Estate of Rosenberg v. Commissioner, 73 T.C. 1014,
1017-1018 (1980); Hays Corp. v. Commissioner, 40 T.C. 436,
442-443 (1963), affd. 331 F.2d 422 (7th Cir. 1964). In addition,
we are bound by the constraints imposed by the Internal Revenue
Code, and any ability we have to grant Ms. Lewallen relief from
complete joint and several liability must be made within section
6015’s framework.
1. Relief Under Section 6015(b)
Section 6015(b) provides full or apportioned relief from
joint and several liability for tax (including interest,
penalties, and other amounts) to the extent that such liability
is attributable to an understatement of tax. To be eligible for
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