-57-
them. While we apply a Natl. Muffler analysis, our result under
a Chevron analysis would be the same.
X. Review of the Disputed Regulations
A. Overview
We conclude that the timely filing requirement in the
disputed regulations does not harmonize with the plain language,
origin, or purpose of the relevant text of section 882(c)(2). A
plain reading of the relevant text in the context of the Internal
Revenue Code shows that the text includes no timely filing
requirement. Where, as here, the Secretary has prescribed a
regulation that is inconsistent with the plain meaning of a
statute, the regulation is invalid, and any deference to the
Secretary’s interpretation of that statute under Natl. Muffler
Dealers Association v. United States, 440 U.S. 472 (1979), is
unwarranted. Such is especially so where, as here, the disputed
regulations also are unreasonable under an analysis of Natl.
Muffler Dealers Association v. United States, supra at 477.
B. Plain Meaning of the Relevant Text
We begin our analysis of the relevant text with the words
used therein. We apply the plain meaning of the words used in a
statute unless we find that a word’s plain meaning is ambiguous.
See Garcia v. United States, 469 U.S. 70, 76 n.3 (1984); see also
Ex parte Collett, 337 U.S. 55 (1949). When interpreting a
statute, “[t]he judiciary is the final authority on issues of
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