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extant, present, or available : be left when the rest is gone”.
The word “remain” can also mean “to be something yet to be shown,
done, or treated”. Remain also can mean “to stay in the same place
or with the same person or group”. Finally, remain can mean “to
continue unchanged in form, condition, status, or quantity”,
“continue to be”, or “stand”.
Respondent asserts that the word “remaining” is used
throughout the Internal Revenue Code “almost exclusively” to mean
that portion which is left over from the whole. We agree that the
word “remaining” often refers to what is left; i.e., the remaining
amount; e.g., sections 72(s)(1)(A), 74(c)(2), 170(l), 172(f)(5),
401(a)(9)(B)(i)(II), 414(k)(2), 671, 864(f)(1)(C), and 865(c)(1)(B)
refer to “the remaining portion”,10 and sections 169(a) and 194(a)
10 See also, sec. 25(a)(1)(B) (“the remaining principal”);
sec. 6861(f) (“any remaining portion”); sec. 451(h)(2)(A) (“a
qualified prize (or remaining portion thereof)”); sec. 148(f)(3)
(“the remaining balance”); sec. 6340(c)(3) (“the remaining balance
of such liability”); sec. 263A(d)(2)(B)(ii) (“any part of the
remaining equity interest”); sec. 408A(d)(3)(E)(ii) (“all remaining
amounts””); sec. 904(f)(3)(A)(i) (“the remaining amount”); sec.
996(a)(2) (“the remaining 1/17th of such amount”); sec. 565(f)(1)
(“all the remaining earnings and profits”); section 732(c)(1)(B)
(“to the extent of any basis remaining after the allocation”, “such
remaining basis”); sec. 1250(d)(4)(D)(ii) (“the remaining gain not
recognized on the transaction”); sec. 4254(a)(2) (“the remaining
items not included in any such group”); sec. 1082(a)(2)(G) (“all
other remaining property”); sec. 1250(f)(3)(C) (“the remaining
property”); sec. 1272(a)(6)(A)(i) (“all remaining payments”); sec.
4943(c)(1) (“the remaining holdings”); sec. 7507(c)(3) (“to the
extent of the remaining assets”); secs. 47(c)(2)(B)(vi),
147(f)(2)(E) (“the remaining term”); sec. 42(j)(6)(B) (“the
remaining compliance period”); sec. 412(b)(4) (“the remaining
amortization period”); sec. 192(c)(1)(B)(i) (“the average remaining
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