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and manner as the Secretary may require.
(B) Exception where individual has
guardian, etc.--An individual shall not be
treated as financially disabled during any
period that such individual’s spouse or any
other person is authorized to act on behalf
of such individual in financial matters.
A plain reading of section 6511(h) demonstrates that the
physical or mental impairment must be that of the taxpayer, not
of some third person. See United States v. Ron Pair Enters.,
Inc., 489 U.S. 235, 241 (1989) (“The task of resolving the
dispute over the meaning of * * * [a statute] begins where all
such inquiries must begin: with the language of the statute
itself * * * In this case it is also where the inquiry should
end, for where, as here, the statute’s language is plain, ‘the
sole function of the courts is to enforce it according to its
terms.’”). In defining “financially disabled”, section
6511(h)(2)(A) refers to “a medically determinable physical or
mental impairment of the individual” to whom the statute of
limitations applies. (Emphasis added.) To have any logical
meaning, the statute must equate “the individual” with the
taxpayer claiming the benefits of section 6511(h). Furthermore,
Congress clearly intended that the physical or mental impairment
of the taxpayer be substantial. First, the impairment must be
one that is “expected to result in death or which has lasted or
can be expected to last for a continuous period of not less than
12 months.” Sec. 6511(h)(2)(A). Secondly, to claim these
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