-60-
include both meanings in a single provision. See, e.g., 1954
Code secs. 6033(b), 6036, 6081(b), 6103(b)(1) and (d)(1)(B),
6201(a), 6205(a)(1) and (b), 6302(c), 6335(b), 6338(b), 6413(b),
7204 for instances where Congress upon enactment of the 1954 Code
used both words in a single provision in subtitle F (then secs.
6001 through 7852). Congress did likewise in the Foreign
Investors Tax Act of 1966, when it legislated as to section 882,
and in the 1986 Code, when it recodified the relevant text a
second time. As to the former legislation, see, e.g., secs. (as
amended by the Foreign Investors Tax Act of 1966) 871(d)(3),
981(d). As to the latter legislation, see, e.g., 1986 Code secs.
6033(b), 6036, 6038(a)(2), 6038A(a), 6038B(a), 6039C(c)(4),
6039D(a) and (c), 6039F(a)(1), 6045(d), 6047(b), 6050A(a),
6050K(a), 6053(c)(1), 6059(c), 6081(b), 6096(c), 6103(f)(4)(A)
and (B) and (p)(1), 6104(a)(1)(A), 6157(a)(2), 6164(b),
6166(b)(7), 6167(a), 6201(a), 6205(a)(1) and (b), 6230(i),
6302(c), 6324A(a) for instances where Congress upon enactment of
the 1986 Code used both words in a single provision in subtitle F
(then secs. 6001 through 7872); see also 1986 Code sec. 6039(a)
(stating the specific time by which a “written statement” must be
furnished “in such manner and setting forth such information as
the Secretary may by regulations prescribe”).
We believe that Congress acted intentionally and purposely
when it included both “time” and “manner” in single sections of
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