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similarly, stating that revenue rulings are entitled to limited
deference. See Bankers Life & Cas. Co. v. United States,
142 F.3d 973, 978 (7th Cir. 1998); First Chicago NBD Corp. v.
Commissioner, 135 F.3d 457 (7th Cir. 1998); see also U.S.
Freightways Corp. v. Commissioner, 270 F.3d 1137, 1141 (7th Cir.
2001) (discussing the level of deference owed to agency
interpretations after United States v. Mead Corp., supra), revg.
113 T.C. 329 (1999). The Commissioner also recognizes the
limited strength of a revenue ruling, explaining in his
procedural rules that “The conclusions expressed in Revenue
Rulings will be directly responsive to and limited in scope by
the pivotal facts stated in the revenue ruling”, sec.
601.601(d)(2)(v)(a), Statement of Procedural Rules, and “Revenue
Rulings published in the Bulletin do not have the force and
effect of Treasury Department Regulations”, sec.
601.601(d)(2)(v)(d), Statement of Procedural Rules.
In United States v. Mead Corp., supra, the Supreme Court
considered the degree of judicial deference afforded to a ruling
by the U.S. Customs Service as to a tariff classification. The
Court stated: “We agree that a tariff classification has no
claim to judicial deference under Chevron, there being no
indication that Congress intended such a ruling to carry the
force of law, but we hold that under Skidmore v. Swift & Co.,
323 U.S. 134 (1944), the ruling is eligible to claim respect
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