-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 toPage: 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