-27- 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,Page: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
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