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statute to override the plain meaning of the words used therein.
See Hirasuna v. Commissioner, 89 T.C. 1216, 1224 (1987);
Huntsberry v. Commissioner, 83 T.C. 742, 747-748 (1984). The
legislative history of the statutes relevant to this case
contains no evidence that Congress intended that there be any
adjustment to account for inflation.
As with the statutes, the regulations also contain no
mention of inflation adjustments. The regulations under section
72 are interpretative regulations. Such regulations must be
upheld “unless unreasonable and plainly inconsistent with the
revenue statutes”. Commissioner v. South Tex. Lumber Co., 333
U.S. 496, 501 (1948). The regulations under section 72 are not
unreasonable and are not plainly inconsistent with the statute
with respect to the issue presented in the instant case.
The regulations promulgated under section 72 are of long
standing, originally adopted on November 14, 1956, by T.D. 6211,
1956-2 C.B. 29. While there have been numerous amendments to the
regulations, none have affected the issue at bar. With respect
to the longevity of these regulations, the Supreme Court has
stated that long-standing rules should not be overruled except
for weighty reasons. See Commissioner v. Sternberger’s Estate,
348 U.S. 187, 199 (1955). As discussed below, there are no such
weighty reasons in the instant case.
While there are no cases directly on point dealing with
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