Cite as: 520 U. S. 93 (1997)
Scalia, J., dissenting
to be used to pay expenses incurred in the administration of the estate." (Emphasis added.)
This text was issued pursuant to explicit authority given the Secretary of the Treasury to promulgate the rules and regulations necessary to enforce the Internal Revenue Code. See 26 U. S. C. § 7805(a). As this Court has repeatedly acknowledged, judicial deference to the Secretary's handiwork "helps guarantee that the rules will be written by 'masters of the subject.' " National Muffler Dealers Assn., Inc. v. United States, 440 U. S. 472, 477 (1979), quoting United States v. Moore, 95 U. S. 760, 763 (1878). Thus, when a provision of the Internal Revenue Code is ambiguous, as § 2056(b)(4)(B) plainly is, this Court has consistently deferred to the Treasury Department's interpretive regulations so long as they " ' "implement the congressional mandate in some reasonable manner." ' " National Muffler Dealers Assn., Inc., supra, at 476, quoting United States v. Cart-wright, 411 U. S. 546, 550 (1973), in turn quoting United States v. Correll, 389 U. S. 299, 307 (1967). See also Cottage Savings Assn. v. Commissioner, 499 U. S. 554, 560-561 (1991).
As the courts below recognized, the crucial term of the regulation for present purposes is "material limitations." Curiously enough, however, neither the Commissioner nor respondent comes forward with a definition of this term, the former simply contending that "it is the burden of paying administration expenses itself that constitutes the 'material' limitation," Brief for Petitioner 31, and the latter simply contending that that burden is for various reasons not substantial enough to qualify. Today's plurality opinion also takes the latter approach, never defining the term but displaying by its examples that "material" must mean "relatively substantial." If, it says, a spouse's bequest represents a small portion of the overall estate and could be expected to generate little income, the estate's anticipated administration expenses " 'may' be material" when compared to the antici-
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