RAWLINSON, Circuit Judge:
Lanny L. Christensen appeals from the Tax Court's summary judgment in favor of the Commissioner of Internal Revenue (Commissioner) on Christensen's claim for equitable relief under 26 U.S.C. § 6015(f). The Tax Court determined that relief under § 6015(f) is available only to spouses who file a joint federal income tax return. Because the plain language, context, and legislative history of § 6015 support the Tax Court's interpretation...
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