Union Carbide Corporation and Subsidiaries - Page 17

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          Respondent maintains that sentence No. 4 allows the FSC and the              
          related supplier to change their administrative pricing method,              
          or the grouping of transactions to which the methods are applied,            
          only if such redeterminations are made while the periods of                  
          limitations for making claims for refund under section 6511 are              
          open for both the FSC and the related supplier (dual section 6511            
          requirement).  Respondent further argues that the dual section               
          6511 requirement extends to any redeterminations made pursuant to            
          sentence No. 5 as well.                                                      
               We agree with respondent.  The Regulation is clear and                  
          unambiguous, and that is where our inquiry as to the meaning of              
          the Regulation must end.  See General Dynamics Corp. & Subs. v.              
          Commissioner, supra at 122.                                                  
               In response to petitioner's principal argument, the                     
          antecedents of the pronoun "their" in sentence No. 4 are                     
          unequivocally the related supplier and the FSC.  Thus, sentence              
          No. 4 on its face mandates that the period of limitations under              
          section 6511 be open for both the related supplier and the FSC in            
          order for FSC commission expenses to be redetermined.                        
               Despite claiming to rely on the plain meaning of the                    
          Regulation, petitioner asks the Court to interpret sentence No. 4            
          essentially as follows:                                                      
               In addition, a redetermination may be made by the FSC                   
               and related supplier if either the related supplier's                   
               or the FSC's taxable year is still open under the                       
               statute of limitations for making claims for refund                     
               under section 6511 if they determine that a different                   




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