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be construed so that each of its provisions is given full effect
and not to render parts of the statute inoperative or
superfluous. See Duke v. University of Texas, 663 F.2d 522, 526
(5th Cir. 1981).
Accordingly, section 6231(c) should be read in its entirety,
as part of a single statutory scheme, and not so as to render
parts of the statute inoperative. Section 6231(c), in pertinent
part, provides as follows:
SEC. 6231(c). Regulations With Respect to Certain
Special Enforcement Areas.--
(1) Applicability of Subsection.--This subsection
applies in case of
* * * * * * *
(B) criminal investigations,
* * * * * * *
(E) other areas that the Secretary determines
by regulation to present special enforcement
considerations.
(2) Items May Be Treated As Nonpartnership Items.
--To the extent that the Secretary determines and
provides by regulations that to treat items as
partnership items will interfere with the effective and
efficient enforcement of this title in any case
described in paragraph (1), such items shall be treated
as non-partnership items for purposes of this
subchapter. [Emphasis added.]
(3) Special Rules.--The Secretary may prescribe by
regulation such special rules as the Secretary
determines to be necessary to achieve the purposes of
this subchapter in any case described in paragraph (1).
[Emphasis added.]
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