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This Court is “not at liberty to supply by construction what
Congress has clearly shown its intention to omit.” Carey v.
Donohue, 240 U.S. 430, 437 (1916); see also INS v.
Cardoza-Fonseca, 480 U.S. 421, 442-443 (1987) (“Few principles of
statutory construction are more compelling than the proposition
that Congress does not intend sub silentio to enact statutory
language that it has earlier discarded in favor of other
language"). The fact that Congress considered an amendment to
section 7430(c)(7) to allow recovery of administrative costs in
situations before the issuance of a notice of deficiency or
Appeals Office decision, but chose not to do so convinces us that
it would be inappropriate to interpret the RRA 1998 amendment of
section 7430(c)(2) by grafting a concomitant amendment onto
section 7430(c)(7).
Finally, we note that neither section 7430(c)(2) nor section
7430(c)(7) is rendered meaningless, or is otherwise contradicted,
by the other. All parts of a statute must be read together, and
each part should be given its full effect. See McNutt-Boyce Co.
v. Commissioner, 38 T.C. 462, 469 (1962), affd. per curiam 324
F.2d 957 (5th Cir. 1963). We find no reason why the language of
each should not be given its full effect. Accordingly, we
interpret section 7430(c)(7) to limit recovery of administrative
costs to those situations in which a notice of deficiency or
Appeals Office decision has been issued. In these situations and
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