- 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of the blanket exemption from taxation of all veterans’ benefits contained in Mim. 4411, XV-1 C.B. 497 (1936) (superseded and reacknowledged in Rev.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.Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 NextLast modified: November 10, 2007