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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)).
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