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standing under section 7476.); Jablonski v. Commissioner, T.C.
Memo. 1998-396; Jones v. Commissioner, supra.
We likewise reject petitioners' contention that section
1.7476-1(b), Income Tax Regs., is invalid. The regulation is the
product of a specific congressional grant of authority to the
Secretary of the Treasury set forth in section 7476(b)(1). As a
legislative regulation, the provision is entitled to greater
deference than an interpretive regulation promulgated under the
general rule-making power vested in the Secretary by section
7805(a). See Peterson Marital Trust v. Commissioner, 102 T.C.
790, 797-798 (1994), affd. 78 F.3d 795, 798 (2d Cir. 1996). To
be valid, section 1.7476-1(b), Income Tax Regs., need not be the
best construction of section 7476(b)(1), only a reasonable one.
See Atlantic Mut. Ins. Co. v. Commissioner, 523 U.S. 382, 389
(1998). Legislative regulations are to be given controlling
weight unless they are arbitrary, capricious, or manifestly
contrary to the statute. See Romann v. Commissioner, supra at
281-282.
The plain language of section 7476(b)(1) reveals that
Congress did not contemplate that every employee would be
considered an "interested party". Moreover, the statute
expressly directs the Secretary to prescribe regulations defining
which employees are to be interested parties. See Romann v.
Commissioner, supra at 289. In accordance with the Court's
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