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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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