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See Dresser Indus., Inc. v. Commissioner, supra at 1137-1138. An
interpretative regulation must be upheld if it "implement[s] the
congressional mandate in some reasonable manner". National
Muffler Dealers Association, Inc. v. United States, 440 U.S. 472,
476-477 (1979) (quoting United States v. Cartwright, 411 U.S.
546, 550 (1973)). In determining whether an interpretative
regulation implements the congressional mandate in some reasona-
ble manner, we must examine whether it "harmonizes with the plain
language of the statute, its origin, and its purpose." National
Muffler Dealers Association, Inc. v. United States, supra at 477.
Such a regulation cannot be declared invalid, unless it is "un-
reasonable and plainly inconsistent with the revenue statutes".
Commissioner v. South Texas Lumber Co., 333 U.S. 496, 501 (1948).
The Supreme Court recently set forth the following standard for
ascertaining the validity of an interpretative regulation:
Under the formulation now familiar, when we confront an
expert administrator's statutory exposition, we inquire
first whether "the intent of Congress is clear" as to
"the precise question at issue." Chevron U.S.A. Inc.
v. Natural Resources Defense Council, Inc., 467 U.S.
837, 842 (1984). If so, "that is the end of the mat-
ter." Ibid. But "if the statute is silent or
ambiguous with respect to the specific issue, the
question for the court is whether the agency's answer
is based on a permissible construction of the statute."
Id., at 843. If the administrator's reading fills a
gap or defines a term in a way that is reasonable in
light of the legislature's revealed design, we give the
administrator's judgment "controlling weight." Id., at
844. [NationsBank v. Variable Annuity Life Ins. Co.,
513 U.S. ___, ___, 115 S. Ct. 810, 813-814 (1995);
citations omitted.]
In determining the validity of an interpretative regulation, the
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