-59-
it intended to include the meanings of both words in a single
statutory provision. See, e.g., 1939 Code secs. 55(b)(1) and
(2), (d)(1)(B), 115(g), 291, 821(b), 864(b), 1203, 1420(c), 1421,
1502, 1522, 1530(b), 1604, 1716, 1902(b), 2190, 2471, 2701,
2802(d)(2), 2803(d), 2854, 2903(c), 2905, 3150(b)(1), 3271,
3310(c), 3448(a), 3461, 3467(b), 3612(e), 3640, 3701, 3704(b),
3975, 3976(a). Many of those instances applied specifically to
the time and manner of the filing of a return. See, e.g., 1939
Code secs. 821(b) and 864(b) (“The return required of the
executor under subsection (a) shall be filed at such times and in
such manner as may be required by regulations made pursuant to
law”), 2471 (“Such returns shall contain such information and be
made at such times and in such manner as the Commissioner, with
the approval of the Secretary, may by regulations prescribe”),
2701 (same language), 3448(a) (same language), 3461 (same
language), 3467(b) (same language); see also 1939 Code secs. 1203
(stating the specific time by which a return must be filed and
that the “return shall contain such information and be made in
such manner as the Commissioner with the approval of the
Secretary may by regulations prescribe”), 1604 (similar
language), 1716 (similar language).
In the 1954 Code, when Congress recodified the relevant text
with a reference to “subtitle F”, Congress continued to use the
words “time” and “manner” together to express its intent to
Page: Previous 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 NextLast modified: May 25, 2011