as imposing a "penalty on married individuals for filing separately” by limiting separately filing spouses to a combined debt limit of $550,000). As we have explained, however, the dissent's view runs contrary not only to-the statute's text ("in the case of a married individual filing a separate return”) but also to the IRS's own uncontested interpretation of the statute. 9 . That said, Congress usually accomplishes this purpose by giving each spouse half the tax benefit that the jointly filing couple gets. That may mean that if a married couple has a large mortgage and files separate returns, but only one spouse seeks the benefit, the couple may, all counted, only get half the benefit it would have received had the couple filed jointly. See, e.g., Bronstein, 138 T.C. at 384, 386 (<HOLDING>). 10 . The statute's definition of qualified
holding that the clear language of  163h3 limited a spouse filing a separate return to 550000 of debt even though she paid all of the mortgage interest and her husband was unable to seek the deduction holding a wife liable for necessary medical expenses incurred by her husband under the doctrine even though the wife did not sign as a guarantor and did not request that her husband be admitted nor anticipate that her husband would be admitted holding that a reservation clause gave a life estate to a spouse pursuant to a deed reserving use of the property to both husband and wife for life even though the husband had no interest in the property holding that debtor who was separated from her husband and who testified that she would only return to the marital home if her husband vacated the house or died or if she was required to care for him or her adult son there or if the couple reconciled was an abandonment of the marital home as her homestead holding that plaintiffs motion to amend her complaint to add her husband as a defendant did not relate back because her failure to sue her husband was not due to misnomer or mistake involving the identity of the proper party but because the law at the time of the complaint did not allow one spouse to sue another in tort