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1976 change, which added section 183(e)(4), eliminated the
requirement for a written agreement that generally waived the
statute of limitations and provided that a section 183(e)
election would automatically extend the limitation period, but
only for "the assessment of any deficiency". The purpose of
section 183(e)(4) was to narrow the scope of the extension
required under prior law. See S. Rept. 94-938 (Part I), supra at
67-69, 1976-3 C.B. (Vol. 3) at 105-107. By enacting section
183(e)(4), Congress limited the subject matter of the new
automatic extension to the "assessment of any deficiency"
attributable to the activity that might be subject to section
183. In Estate of Caporella v. Commissioner, supra, we explained
the purpose of section 183(e)(4):
Without question, the intent of Congress in amending
section 183(e) was to automatically extend the period
of limitations on assessment of deficiencies arising
from "hobby losses" when a taxpayer elects a
postponement of a profit determination. [Id. at 296.]
When it enacted section 183(e)(4), Congress made no provision for
extending the period of limitations for claiming a refund of an
overpayment.
Where a statute appears to be clear on its face, we require
unequivocal evidence of legislative purpose before construing the
statute so as to override the plain meaning of the words used
therein. Huntsberry v. Commissioner, 83 T.C. 742, 747-748
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