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the committee reports accompanying the 1932 Act. No comparable
section was included in the estate tax provisions of the 1932
Act.
Sections 274(g) and 512(g) were incorporated into the
Internal Revenue Code of 1939 by section 272(g) (relating to the
income tax) and section 1012(g) (relating to the gift tax); again
no comparable section was included in the estate tax provisions
of the 1939 Code. This situation remained until the enactment of
the 1954 Code when sections 272(g) and 1012(g) were combined into
section 6214(b). The only legislative history in respect of this
action is the identical comment in the committee reports that
"This section represents no change in existing law". H. Rept.
1337, 83d Cong., 2d Sess. A405 (1954); S. Rept. 1622, 83d Cong.,
2d Sess. 573 (1954). Of interest is the fact that section
6214(b) speaks only of an income tax or gift tax deficiency
although it is included in subchapter B of chapter 63 entitled
"Deficiency Procedures in the Case of Income, Estate, Gift * * *
Taxes".
Granted that there is no legislative explanation as to why
the limitation of the authority of this Court by section 6214(b)
or its antecedents did not extend to the estate tax, the
foregoing analysis of legislative action reinforces our
interpretation that the words "the tax" in section 6214(b) are
limited to income and gift taxes and therefore do not preclude us
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