Chrysler Corporation - Page 9

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          phrase “for such taxable year” to refer to the “any taxable year”           
          specified at the beginning of the same sentence, or, in other               
          words, to the year for which the election of the foreign tax                
          credit is made.  The only other time that Congress used the word            
          “such” in section 901(a) it did so to refer to the “choice” made            
          by the taxpayer described in the first sentence of section                  
          901(a).  We believe it logical to conclude that Congress’ use of            
          the second “such”, i.e., the one at issue, refers to the only               
          “taxable year” described in section 901(a); namely, the year for            
          which the election of the foreign tax credit is made.                       
               Our reading comports with the Commissioner’s regulations               
          prescribed under section 901(a).  Section 1.901-1(d), Income Tax            
          Regs., provides that “The taxpayer may, for a particular taxable            
          year, claim the benefits of section 901 (or claim a deduction in            
          lieu of a foreign tax credit) at any time before the expiration             
          of the period prescribed by section 6511(d)(3)(A)”.  Here,                  
          petitioner aims to “claim the benefits of section 901” for 1980,            
          1981, and 1982 and not for 1985.  The benefits which petitioner             

               views of one Congress as to the meaning of prior                       
               legislation have little bearing on a court's                           
               furtherance of that duty.  Such is especially true in                  
               the instant case where few of the legislators who voted                
               on the subsequent legislation * * * were members of                    
               Congress * * * [at the time of the original                            

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