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          furtherance of their position, petitioners assert that the                  
          Court's more restrictive interpretation of section 6214(a) in               
          Bregin is erroneous on the grounds that (1) the Court's                     
          interpretation impermissibly renders the term "additional amount"           
          a mere redundancy; and (2) the Court violated section 7806(b) by            
          relying on the use of the term "additional amounts" in chapter 68           
          in interpreting the term "additional amount" in section 6214(a).7           
          We disagree with petitioners' assertion that this Court's                   
          interpretation of section 6214(a) in Bregin v. Commissioner, 74             
          T.C. 1097 (1980), renders the term "additional amount" a mere               
          redundancy.  As our detailed analysis of section 6214(a) and its            
          legislative history in Bregin amply demonstrates, Congress used             
          the phrase "any additional amount, or any addition to the tax" in           
          section 6214(a) to ensure an understanding that this Court's                
          jurisdiction encompasses items that are to be assessed,                     
          collected, and paid in the same manner as taxes, including the              

               7Sec. 7806(b) provides in pertinent part:                              
                    SEC. 7806(b).  Arrangement and Classification.--No                
               inference, implication, or presumption of legislative                  
               construction shall be drawn or made by reason of the                   
               location or grouping of any particular section or                      
               provision or portion of this title, nor shall any table                
               of contents, table of cross references, or similar                     
               outline, analysis, or descriptive matter relating to                   
               the contents of this title be given any legal effect.                  
               * * *                                                                  

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