- 15 - U.S. 235, 241 (1989). When the plain language of the statute or regulation is clear and unambiguous, that is where the inquiry should end. General Dynamics Corp. & Subs. v. Commissioner, 108 T.C. at 121-122. On brief, petitioner presents a plenitude of alternative arguments in support of its claims for additional FSC commission expenses for the years in issue. Petitioner's principal contention is that the plain language of sentence No. 4 requires only that the party in the overpayment position file its claims for refund relating to a redetermination of FSC commission expenses within the allowable time period under section 6511. In other words, petitioner maintains that the section 6511 period of limitations need be open only for its own taxes, not those of UCFSC, in order for petitioner to redetermine its FSC commission expenses. Thus, petitioner asserts that it can deduct additional FSC commission expenses in the amounts of $19,176,799, $27,550,019, and $51,218,650 for 1987, 1988, and 1989, respectively, subject to any "correlative adjustments" to UCFSC's returns that, in petitioner's view, are mandated by sentence No. 6 of the Regulation. Petitioner alternatively argues that, even if a "dual statute of limitations requirement" inheres in sentence No. 4, sentence No. 5 literally contains no such requirement. Therefore, petitioner reasons, it is entitled to claim additional expenses in the amounts of $17,578,042, $18,638,279, andPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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