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section 931 confers no benefit of the type contemplated in Estate
of Maddox (i.e., reduction in estate tax due to application of
section 2032A), and First Chicago and Occidental (i.e., relief
from alternative minimum tax liability). Accordingly, these
cases are distinguished.
Second, the grants of authority in Estate of Maddox, First
Chicago, and Occidental allowed the Secretary to promulgate
legislative regulations that enlarged the scope of section 2032A
and the tax benefit rule. The Secretary was not required to
define terms integral to the operation of the entire statute.
Thus, even in the absence of regulations, the Court in those
cases could arrive at a reasonable conclusion regarding whether
the taxpayer met the terms of the statute. See Estate of Maddox
v. Commissioner, supra at 233 (concluding that the language of
section 2032A(g) “backhandedly tells us that Congress did not
want the estate of a stockholder in a family corporation to be
deprived of the benefits of section 2032A”); First Chicago Corp.
v. Commissioner, supra at 672 (reasoning that section 58(h) “was
obviously intended to give the tax benefit rule unlimited
scope”); see also Occidental Petroleum Corp. v. Commissioner,
supra at 827. Congress, in section 931, did not, however,
provide a basis upon which this Court can determine whether
petitioner’s income qualifies for exclusion.
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