- 21 - suggests, Congress intended to limit the scope of the Court’s equitable recoupment authority to taxes that normally fall within the Court’s deficiency and/or overpayment jurisdiction, we are convinced that Congress would have drafted section 6214(b) to say so in clear and unambiguous terms. Nor does the legislative history underlying the amendment to section 6214(b) provide any support for respondent’s position. To the contrary, S. Rept. 109-336, supra at 97, indicates that Congress viewed the amendment to section 6214(b) as a means to provide clarity and simplification for taxpayers and the Commissioner alike. The literal interpretation of section 6214(b) that petitioners advocate, under which the Court is authorized to apply the doctrine of equitable recoupment in respect of all internal revenue taxes, offers clarity and a meaningful measure of simplification in that both parties can be confident that the Court may provide a complete remedy for a given taxable year. In contrast, respondent’s narrow construction of the provision would add uncertainty to litigation and create a category of cases in which equitable recoupment would not be available in the Tax Court. Respondent’s narrow construction of section 6214(b) is also inconsistent with the central policy underlying the doctrine of equitable recoupment; i.e., to prevent an inequitable windfall to a taxpayer or the Government that would otherwise result from thePage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 NextLast modified: March 27, 2008