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circumstances, we shall not rewrite the authorized regulations to
meet petitioner’s concerns. See Newborn v. Commissioner, 94 T.C.
610, 636-637 (1990).
Petitioner also asserts that the Supreme Court’s decision in
Robinson v. Shell Oil Co., 519 U.S. 337 (1997), requires section
7476 to be construed to include petitioner as an interested
party. We disagree.
The careful unanimous opinion of the Supreme Court in
Robinson v. Shell Oil Co. points out that “employee” has a
variety of meanings in sections 701(c), 703(h), 706(g)(1), and
717(a), (b), and (c) of title VII of the Civil Rights Act of
1964, Pub. L. 88-352, 78 Stat. 254, 257, 261, as amended. The
opinion concludes that “employee” as used in section 704(a) of
Pub. L. 88-352, 78 Stat. 257, is ambiguous and further concludes
that the purposes of that section 704(a) would best be served by
construing “employee” to include “former employee.”
In the instant case, the plain language of the statute makes
it clear that not every employee will be an “interested party”.
Also, in the instant case the plain language of the statute
specifically commits to the Treasury Department the task of
defining which employees are to be interested parties. Finally,
in the instant case the regulations promulgated under this
specific grant of authority make it clear that under some
circumstances certain former employees can be interested parties.
Thus, the analysis appearing in Robinson v. Shell Oil Co., supra,
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