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year which shall be deemed to have been paid or accrued
in such preceding or subsequent taxable year * * *
Petitioner argues that section 904(c) is a clear legislative
expression that interest is not imposed on tax liability "paid"
by foreign tax carrybacks, because such carrybacks are "deemed
taxes paid or accrued to foreign countries * * * in" (emphasis
added) the year to which they are carried back and no statutory
provision exists that contradicts this plain language.
Petitioner describes the various interest provisions in the
Internal Revenue Code as detailed and complex and points to the
absence of a specific interest provision concerning foreign tax
carrybacks in situations involving deficiencies as significant in
light of other provisions dealing with the question of interest
on deficiencies involving other types of carrybacks. Respondent
urges us to preserve symmetry between the treatment of interest
on deficiencies with that of interest on overpayments in the
foreign tax carryback situation, in keeping with Manning v.
Seeley Tube & Box Co., supra; United States v. Koppers Co., 348
U.S. 254 (1955), and the recently decided Fluor Corp. &
Affiliates v. United States, 126 F.3d 1397 (Fed. Cir. 1997).
We begin our analysis of the scope of the language of
section 904(c) mindful of our observations in Hospital Corp. of
Am. v. Commissioner, 107 T.C. 73, 84-85 (1996):
The language of a statute * * * cannot be viewed in
isolation. In construing the meaning of [a] section
* * *, it is necessary to consider all of the words of
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