Swallows Holding, Ltd. - Page 103

                                        -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  Next

Last modified: May 25, 2011