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Thus, before the enactment of the 1954 Code, a foreign
corporation such as petitioner was required to file its Federal
income tax returns at Baltimore, Maryland.
Since the enactment of the 1954 Code, a corporation
generally must file its Federal income tax returns with the
District Director for the internal revenue district in which is
located the corporation’s principal place of business, principal
office, or agency. See sec. 6091(b)(2)(A); see also sec.
1.6091-2(b), Income Tax Regs. The rule is different where a
foreign corporation has no principal place of business, principal
office, or agency in any internal revenue district. See sec.
6091(b)(2)(B)(i), (iii). In that case, section 6091(b)(2)(B)(i)
and (iii) allows the Secretary to designate by regulation the
place where the foreign corporation’s return will be filed.
As relevant here, section 1.6091-3(f), Income Tax Regs.
(before amendment on September 15, 2004, by T.D. 9156, 2004-2
C.B. 669, 671), generally required that a foreign corporation
file its Federal income tax returns with the “Director of
International Operations, Internal Revenue Service, Washington,
D.C. 20225, or the district director, or the director of the
service center, depending on the appropriate officer designated
on the return form or in the instructions issued with respect to
such form”. That section was issued by the Secretary in 1959.
See T.D. 6364, 1959-1 C.B. 546, 604. In the 1972 instructions
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