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(e.g., deficiency cases, section 6015(e) spousal relief
cases, or section 6330 collection proceedings).
Schwartz involved a section 6330 collection proceeding where the
election to proceed as a small tax case was governed by section
7463(f)(2). The instant case involves a section 6015(e) spousal
relief proceeding where the election to proceed as a small tax
case is governed by section 7463(f)(1). Therefore, we must
analyze the distinct language in section 7463(f)(1) applicable to
section 6015(e) spousal relief cases.
Section 7463(f) provides:
SEC. 7463(f). Additional Cases in Which
Proceedings May Be Conducted Under This Section.–-At
the option of the taxpayer concurred in by the Tax
Court or a division thereof before the hearing of the
case, proceedings may be conducted under this section
(in the same manner as a case described in subsection
(a)) in the case of--
(1) a petition to the Tax Court under
section 6015(e) in which the amount of relief
sought does not exceed $50,000, and
(2) an appeal under section
6330(d)(1)(A) to the Tax Court of a
determination in which the unpaid tax does
not exceed $50,000. [Emphasis added.]
In interpreting a statute, our purpose is to give effect to
Congress’s intent. Fernandez v. Commissioner, 114 T.C. 324, 329
(2000); see also Gati v. Commissioner, 113 T.C. 132, 133 (1999).
We begin with the statutory language. Allen v. Commissioner, 118
T.C. 1, 7 (2002) (and cases cited thereat). Usually, the plain
meaning of the statutory language is conclusive. United States
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