The Coca-Cola Company, and Includible Subsidiaries - Page 29

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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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