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for making redeterminations pursuant to sentence No. 5. Rather,
we conclude that the dual section 6511 requirement set forth in
sentence No. 4 applies equally to redeterminations of FTGR and
the amounts of costs and expenses used to redetermine profits of
the FSC and the related supplier under the transfer pricing
methods of section 925(a). In that connection, we observe that
sentence No. 5 begins with the word "also". According to
Webster's II New Riverside University Dictionary (1988), "also"
means "in addition: likewise." Moreover, the preamble to the FSC
regulations states in pertinent part that a
redetermination may be made by the FSC and related
supplier if their taxable years are open under the
statute of limitations for making claims for refund
under section 6511 if they determine that a different
transfer pricing method or grouping of transactions
would be more beneficial. Likewise, * * * [the FSC and
related supplier] may redetermine the amount of * * *
[FTGR] and the costs and expenses that are used to
determine their profit under the transfer pricing
methods. * * * [T.D. 8126, 1987-1 C.B. at 189;
emphasis added.]
Petitioner has failed to persuade us that sentence No. 5
should be read inconsistently with, and divorced from, the
requirement announced in sentence No. 4. Regulations, like
statutes, "are to be considered, each in its entirety and not as
if each of its provisions was independent and unaffected by the
others." Alexander v. Cosden Pipe Line Co., 290 U.S. 484, 496
(1934); see General Dynamics Corp. & Subs. v. Commissioner, 108
T.C. at 121.
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