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Petitioner counters that section 301.6320-1(b)(1) and (2),
Proced. & Admin. Regs., is an interpretative regulation
promulgated under section 7805(a)4 that is entitled to very
little deference and, in any event, the regulation is
inconsistent “with the letter and the spirit of Section 6320.”
It is well settled that an interpretative Treasury
Department regulation is valid if it implements a congressional
mandate in a reasonable manner. See Natl. Muffler Dealers
Association, Inc. v. United States, 440 U.S. 472, 476-477 (1979)
(citing United States v. Cartwright, 411 U.S. 546, 550 (1973)).
An interpretative Treasury Department regulation is reasonable
under Natl. Muffler Dealers Association, Inc. v. United States,
supra, if it "harmonizes with the plain language of the statute,
its origin, and its purpose." Id. at 477; see also United States
v. Vogel Fertilizer Co., 455 U.S. 16, 26 (1982).
As previously discussed, the language of section 6320 does
not address explicitly the precise point we must decide in this
case. Where a statute is ambiguous or silent, we may look to the
statute’s legislative history to determine congressional intent.
See, e.g., Burlington N. R.R. v. Okla. Tax Commn., 481 U.S. 454,
461 (1987). In this case, Congress directly addressed the
question at issue in the legislative history underlying section
4 Sec. 7805(a) provides in pertinent part that “the
Secretary shall prescribe all needful rules and regulations for
the enforcement of this title”.
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