Swallows Holding, Ltd. - Page 73

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          revenue acts of the words “manner” and “time” and by literally              
          applying the word “manner” in accordance with the word’s “usual             
          and ordinary meaning of ‘mode, method, mien, style, or way’”.               
          Id. at 715.  The Board concluded that the word “manner” was not             
          intended by Congress to, and thus did not, include any element of           
          time, let alone impose a requirement that a foreign corporation             
          file its return by a certain date in order to deduct its                    
          expenses.  Id. at 714-716.  The Board stated:  “A careful reading           
          of sections 233 and 235 discloses no indication of a legislative            
          intent to extend the meaning of ‘manner’ so as to include ‘time’.           
          Neither section provides that the deductions may not be allowed             
          unless the return is filed within the time prescribed.”  Id. at             
          715.  The Board added that if Congress had intended to deprive a            
          foreign corporation of its right to a deduction when it did not             
          file a timely Federal income tax return, it would have said so.             
          Id.  The Board also supported its conclusion by analyzing the               
          “structure” of the revenue acts.  The Board concluded from that             
          analysis:                                                                   
               They seem to have a more or less common pattern.  Thus                 
               section 52 governs the manner of filing corporation                    
               returns, section 215(a) deals with the manner of filing                
               returns by or for nonresident aliens, section 251(f)                   
               the manner of filing returns by citizens of the United                 
               States who are in receipt of income from sources within                
               possessions of the United States, and section 233 the                  
               manner of filing returns for a foreign corporation.                    
               Sections 53, 217, and 235 deal with the time and place                 
               of filing returns, while sections 56, 218, and 236 deal                
               with payment.  Inasmuch as separate sections deal with                 
               “manner” and “time”, we think it highly improbable that                





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