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The Internal Revenue Code contains numerous specific
delegations of authority from Congress to the Secretary or the
Commissioner to issue rules or regulations that have the force
and effect of law. See, e.g., sec. 1502. These sections--that
provide for issuing legislative regulations--would be superfluous
if section 7805 were a delegation of authority from Congress to
make rules or regulations carrying the force of law. It is a
fundamental rule of statutory construction to give effect to all
of the language of the statute. See Hellmich v. Hellman, 276
U.S. 233 (1928); Stanford v. Commissioner, 297 F.2d 298, 308 (9th
Cir. 1961), affg. 34 T.C. 1150 (1960); Larkin v. United States,
78 F.2d 951 (8th Cir. 1935); Stolk v. Commissioner, 40 T.C. 345
(1963), affd. per curiam 326 F.2d 760 (2d Cir. 1964). It is a
well-accepted rule of statutory construction that the various
sections of the Code should be construed so that one section will
explain and support and not defeat or destroy another section.
Crane v. Commissioner, 331 U.S. 1, 13 (1947); Bernier v. Bernier,
147 U.S. 242, 246 (1893); Pleasanton Gravel Co. v. Commissioner,
85 T.C. 839, 851 (1985). Accordingly, I believe that section
7805 is not a delegation of authority by Congress to make rules
or regulations carrying the force of law.
IV. Mead Applied to Interpretive Regulations
Prior to Mead, we questioned whether Chevron applies to
interpretive regulations. Cent. Pa. Sav. Association & Subs. v.
Commissioner, 104 T.C. 384, 391 (1995) (citing E.I. duPont de
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