Union Carbide Corporation and Subsidiaries - Page 19

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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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