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v. Ron Pair Enters., Inc., 489 U.S. 235, 242 (1989); Woodral v.
Commissioner, 112 T.C. 19, 23 (1999). “When a statute appears to
be clear on its face, there must be unequivocal evidence of
legislative purpose before interpreting the statute so as to
override the plain meaning of the words used therein.” Fernandez
v. Commissioner, supra at 330; see also Huntsberry v.
Commissioner, 83 T.C. 742, 747-748 (1984). If the statute is
ambiguous or silent, we may look to the statute’s legislative
history to determine congressional intent. Burlington N. R.R. v.
Okla. Tax Commn., 481 U.S. 454, 461 (1987); Fernandez v.
Commissioner, supra at 329-330.
We must decide what constitutes the “amount of relief
sought” within the meaning of that phrase as contained in section
7463(f)(1). Respondent argues that the “amount of relief sought”
within the meaning of section 7463(f)(1) includes the amount of
paid or unpaid tax, interest, and penalties, including accrued
but unassessed interest and penalties, for which the electing
spouse is seeking relief under section 6015. While the phrase
“amount of relief sought” is not statutorily defined, our
analysis of the relief available under section 6015 supports
respondent’s position.
An electing spouse who qualifies for section 6015(b)(1)
relief “shall be relieved of liability for tax (including
interest, penalties, and other amounts) for such taxable year to
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