- 24 - result which Congress could hardly have intended in enacting the FSC legislation, notwithstanding its interest in promoting foreign trade. See Faltesek v. Commissioner, supra at 1210-1211. Petitioner contends that, in a lengthy audit, to the extent it is respondent's policy to refuse to grant consents solely for the purpose of extending the period for taxpayers to file claims for refund, the Regulation unreasonably bars the related supplier from claiming additional expenses after the period of limitations under section 6511 with respect to the FSC has expired. We disagree. Far from being arbitrary or unreasonable, the fact that the Secretary chose to confine taxpayers' redeterminations to a period which may be extended instead of a fixed timeframe indicates to us that the Secretary was mindful that a closed-end period conceivably could bar redeterminations in the case of a lengthy audit. Cf. id. at 1211-1212. In the case before us, petitioner made no attempt to secure an extension for UCFSC to file claims for refund for the years at issue. Moreover, it is not respondent's policy to deny invariably such extensions. See 2 Audit, Internal Revenue Manual (CCH), sec. 4541.6, at 8161-17 ("A consent, the sole purpose of which is to extend the period for filing claims for refund, should not be accepted unless the Chiefs, Examination Division * * *, authorizes [sic] the acceptance * * * [thereof]." (Emphasis added)).Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011