Swallows Holding, Ltd. - Page 113

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          taxpayers and their investment in real property in the United               
          States; petitioner invested in the U.S. real estate and                     
          voluntarily filed Federal income tax returns reporting that                 
          income net of the expenses related thereto.                                 
               For sake of completeness, we also note the legislative                 
          reenactment doctrine.  Under that doctrine, Congress is presumed            
          to have known of the administrative and judicial interpretations            
          of a statutory term reenacted without significant change and to             
          have ratified and included that interpretation in the reenacted             
          term.  See Newark Morning Ledger Co. v. United States, 507 U.S.             
          at 574-576; Pierce v. Underwood, 487 U.S. 552, 567 (1988);                  
          Merrill Lynch, Pierce, Fenner & Smith, Inc. v. Curran, 456 U.S.             
          353, 381-382 (1982); Lorillard v. Pons, 434 U.S. 575, 580-581               
          (1978); see also Dresser Indus. v. United States, 238 F.3d 603,             
          614 (5th Cir. 2001); Kovacs v. Commissioner, 100 T.C. 124,                  
          129-130 (1993), affd. without published opinion 25 F.3d 1048                
          (6th Cir. 1994); cf. Cannon v. Univ. of Chicago, 441 U.S. 677,              
          696-697 (1979) (“It is always appropriate to assume that our                
          elected representatives, like other citizens, know the law”.).              
          See generally 2A Sands, Sutherland on Statutory Construction                
          � 49.09 (4th ed. 1973), and cases cited therein.  The legislative           
          reenactment doctrine applies with vigor where Congress reenacts             
          statutory text mainly in its entirety, see Dutton v. Wolpoff                
          & Abramson, 5 F.3d 649, 655 (3d Cir. 1993), or where a prior                






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