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construed so that our jurisdiction is restricted in all events to
taxes within our original jurisdiction.
Petitioners assert that respondent is attempting to add
words of limitation to the otherwise plain language of section
6214(b). Petitioners maintain that section 6214(b) is broadly
worded and clearly expresses Congress’s intent to put this Court
on equal footing with other Federal trial courts vested with
jurisdiction over civil tax disputes. Petitioners argue that to
the extent other Federal trial courts with jurisdiction over
civil tax cases may apply the doctrine of equitable recoupment in
respect of hospital tax, the Tax Court may do so as well.
As explained below, we reject respondent’s narrow
construction of section 6214(b). Respondent’s position regarding
our authority to apply the doctrine of equitable recoupment
conflicts with the plain language of section 6214(b), its
legislative history, and the policies underlying the doctrine.
When Congress recently amended section 6214(b), it confirmed
in the broadest of terms our authority to apply the doctrine of
equitable recoupment. The plain language of section 6214(b)
offers no justification or support for the narrow construction
that respondent advocates. Section 6214(b) simply states that
the scope of the Court’s authority to apply the doctrine of
equitable recoupment is equal to that of other Federal trial
courts with jurisdiction over civil tax cases. If, as respondent
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