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respect to each notice of deficiency.
It is not at all unusual for the Congress to act more
broadly than the confines of the problem described in the
legislative history; the Congress has done so in many different
areas of the tax law. See, e.g., Bartels Trust for Ben. of Univ.
v. United States, 209 F.3d 147, 153-154 (2d Cir. 2000) (relating
to charities’ unrelated trade or business income); Corn Belt Tel.
Co. v. United States, 633 F.2d 114, 117-118 (8th Cir. 1980)
(relating to the definition of “public utility property” for
investment credit purposes); Warrensburg Board & Paper Corp. v.
Commissioner, 77 T.C. 1107, 1110-1111 (1981) (relating to
subchapter S corporations’“one-shot” elections); Estate of Beal
v. Commissioner, 47 T.C. 269, 271-272 (1966) (relating to
includability of the value of certain annuities in decedents’
estates). Where the Congress has chosen to so legislate, the
courts do not confine the statute to the original problem, but
rather apply the statute to the wider net that the Congress has
cast.
The legislative history does not explain why the Congress
chose to use statutory language that is broader than the problem
it sought to address. However, it is plain that the Congress
required the Commissioner to provide assistance on each notice of
deficiency, and not merely where the assistance was, or might be,
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