- 30 -
section 5301(a) (2000); i.e., section 122(a)(4) (1965) of the
Internal Revenue Code of 1954 and 38 U.S.C. section 3101 (1964),
respectively. Indeed, there is no mention of those provisions or
of respondent’s acknowledgment of the blanket exemption from
taxation of all veterans’ benefits contained in Mim. 4411, XV-1
C.B. 497 (1936) (superseded and reacknowledged in Rev. Rul. 72-
605, 1972-2 C.B. 35). Lacking any consideration of the exemption
for veterans’ benefits, the analysis of the ruling is neither
complete nor persuasive.
Finally, respondent argues that, since Congress has amended
what is now 38 U.S.C. section 1718 numerous times since the
Commissioner issued Rev. Rul. 65-18, supra, it must have approved
of the conclusion the Commissioner there reached. A revenue
ruling incorporating a long-standing administrative practice
sanctioned by the Congress or the Courts may acquire the force of
law. Am. Campaign Acad. v. Commissioner, 92 T.C. 1053, 1070
(1989). Nevertheless, we reject respondent’s argument for the
reasons expressed in Ashland Oil, Inc. v. Commissioner, 95 T.C.
348, 363 (1990):
Respondent has not, however, shown that Congress has
been even aware of this administrative interpretation,
which has not been litigated in a reported decision and
has been cited in only a smattering of private letter
rulings. Without affirmative indications of
congressional awareness and consideration, we decline
to cloak this revenue ruling with the aura of
legislative approval. See Commissioner v. Glenshaw
Glass Co., 348 U.S. 426, 431 (1955); Interstate Drop
Forge Co. v. Commissioner, 326 F.2d 743, 746 (7th Cir.
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