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The Committee believes it to be impractical to attempt
by legislation to prescribe the various detailed and
complicated rules necessary to meet the many differing
and complicated situations. Accordingly, it has found
it necessary to delegate power to the Commissioner to
prescribe regulations legislative in character covering
them. * * *
See also Tate & Lyle, Inc. & Subs. v. Commissioner, 103 T.C. 656
(1994).
Section 1.936-6(b), Income Tax Regs., is a legislative
regulation containing substantive rules. As such, the regulation
is entitled to greater weight and deference than an interpretive
regulation issued pursuant to the Commissioner's general grant of
authority to prescribe needful rules and regulations under
section 7805(a). CWT Farms, Inc. v. Commissioner, supra at 800;
Tate & Lyle, Inc. & Subs. v. Commissioner, supra at 666; Perkin-
Elmer Corp. & Subs. v. Commissioner, 103 T.C. 464 (1994).
A legislative regulation is made pursuant to a specific
grant of authority, often without precise congressional guidance,
to define a statutory term or prescribe a method of executing a
statutory provision. Chevron U.S.A., Inc. v. Natural Res. Def.
Council, Inc., 467 U.S. 837, 843-844 (1984); Anderson, Clayton &
Co. v. United States, 562 F.2d 972 (5th Cir. 1977).
In section 936(h)(7), Congress has delegated to the
Commissioner authority to act in an essentially legislative
manner to fill in the gaps of the statute. If the Commissioner's
interpretation is reasonable, it will not be supplanted with our
own. Florida Manufactured Housing Association, Inc. v. Cisneros,
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