Swallows Holding, Ltd. - Page 28

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          Wall Paper & Paint Co., 63 F.2d 701, 702 (3d Cir. 1933) (as                 
          offer “contained no time limitation for acceptance, it was                  
          incumbent upon the plaintiff to accept within a reasonable                  
          time”); Minneapolis & St. Louis R.R. Co. v. Columbus Rolling-               
          Mill Co., 119 U.S. 149, 151 (1886) (“[i]f the offer does not                
          limit the time for its acceptance, it must be accepted within a             
          reasonable time”).                                                          
               I’m not saying that we need to canvass contract law to                 
          construe the Code, only suggesting that the observation that                
          Congress used the word “manner” without specifying “time” is not            
          the end of the argument.  The context in which the word occurs              
          suggests that imputation of a reasonable time limit is not a                
          departure from the ordinary legal meaning of the word--any more             
          than imputation of a reasonable delivery time in a contract for             
          delivery of specified goods, 1 Restatement, Contracts 2d sec. 33            
          (1981), or imputation of a reasonable time for closing a                    
          conveyance of property, 1 Restatement, Property (Mortgages) 3d              
          sec. 7.2 (1997) would be.  And before today, I knew of no place             
          in the Code where a Court has held that “manner” without “time”             
          means “anytime at all.”                                                     
               The reason for imputing some time limits on filing returns             
          or making elections is one of practical necessity.  And this is             
          where the majority’s invocation of Anglo-American is so                     
          unintentionally radical, because the second problem with its                





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