Union Carbide Corporation and Subsidiaries - Page 27

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          so as to create a corresponding deficiency for UCFSC inasmuch as             
          petitioner did not meet the dual section 6511 requirement, and               
          UCFSC is not a party in this case.  Whether or not, under the                
          scenario conjured up by petitioner, respondent would be able to              
          assess deficiencies against the FSC, notwithstanding the                     
          expiration of the period of limitations under section 6501, is               
          not a question before us, and we need not speculate about it.                
               We conclude that the Regulation's dual section 6511                     
          requirement imposed on taxpayers represents a "reasonable                    
          accommodation of the competing interests of fairness,                        
          administrability, and avoidance of abuse."  Atlantic Mut. Ins.               
          Co. v. Commissioner, 523 U.S. ___, ___ 118 S. Ct. 1413, 1415                 
          (1998).  In reaching our conclusion, we recognize that the                   
          Regulation conceivably could have been written in other ways,                
          including the manner advocated by petitioner.  Cf. L & F Intl.               
          Sales Corp. v. United States, 912 F.2d 377, 381 (9th Cir. 1990).             
          However, such a possibility is extraneous to our inquiry.  See,              
          e.g., National Muffler Dealers Association, Inc. v. United                   
          States, 440 U.S. at 488 ("The choice among reasonable                        
          interpretations is for the Commissioner, not the courts."); E.I.             
          du Pont de Nemours & Co. v. Commissioner, 41 F.3d at 136; Brown              
          v. United States, 890 F.2d 1329, 1338 (5th Cir. 1989).                       
          Petitioner has failed to convince us that the Regulation is                  
          either unreasonable or inconsistent with the underlying statute,             






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