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Seventh and that the Comptroller therefore has discretion to
authorize activities beyond those specifically enumerated.”)
C. Court’s Function in Interpreting the Internal Revenue
Code
This Court's function in interpreting the Internal Revenue
Code is to construe the statutory language to effectuate the
intent of Congress. See United States v. Am. Trucking
Associations, 310 U.S. 534, 542 (1940); Merkel v. Commissioner,
109 T.C. 463, 468 (1997); Fehlhaber v. Commissioner, 94 T.C.
863, 865, affd. 954 F.2d 653 (11th Cir. 1992); U.S. Padding Corp.
v. Commissioner, 88 T.C. 177, 184, (1987), affd. 865 F.2d 750
(6th Cir. 1989). Both a textual analysis of the statute and a
consideration of Congress’ purpose in enacting Subpart F are
warranted and appropriate to determine whether deposits with
WFNNB, whose activities were predominantly limited to credit card
transactions, and which is a wholly owned subsidiary of
petitioner, are section 956 deposits. See Public Citizen v.
United States Dept. of Justice, 491 U.S. 440 (1989). We begin by
considering Congress' purpose in enacting subpart F.
D. Tax Reform Acts of 1962 and 1976
Subpart F was added to the Internal Revenue Code of 1954 by
section 12 of the Revenue Act of 1962, Pub. L. 87-834, 76 Stat.
960. H.R. 10650, 87th Cong., 2d Sess. (1962) (H.R. 10650), is
the bill that, when enacted, became the Revenue Act of 1962. The
committee reports accompanying H.R. 10650, both in the House of
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