Cite as: 520 U. S. 93 (1997)
Scalia, J., dissenting
lar decrease in value is "material" enough to qualify—without any hint as to what might be a "ballpark" figure, or indeed any hint as to whether there is such a thing as "absolute materiality" (the $2 million at issue here, for instance), or whether it is all relative to the size of the estate. One should not needlessly impute such a confusing meaning to a regulation which readily bears another interpretation that is more precise. Moreover, the Commissioner's interpretation of her own regulation, so long as it is consistent with the text, is entitled to considerable deference, see National Muffler Dealers Assn., Inc., supra, at 488-489; Cottage Savings Assn., supra, at 560-561.
The concurrence contends that the other (more unnatural) reading of "material" must be adopted—and that no deference is to be accorded the Commissioner's longstanding approach of reducing the marital deduction for any payment of administrative expenses out of marital-bequest income— because of a recent Revenue Ruling in which the Commissioner acquiesced in lower court holdings that the marital deduction is not reduced by the payment from the marital bequest of interest on deferred estate taxes. Ante, at 118- 120 (discussing Rev. Rul. 93-48). The concurrence asserts that interest accruing on estate taxes "is functionally indistinguishable" from administrative expenses, so that Revenue Ruling 93-48 "created a quantitative rule" shielding some financial burdens from affecting the calculation of the marital deduction. Ante, at 118, 119. I think not. The Commissioner issued Revenue Ruling 93-48 only after her contention, that § 20.2056(b)-4(a) required the marital deduction to be reduced by payment of estate tax interest from the marital bequest, was repeatedly rejected by the Tax Court and the Courts of Appeals. See, e. g., Estate of Street v. Commissioner, 974 F. 2d 723 (CA6 1992); Estate of Whittle v. Commissioner, 994 F. 2d 379 (CA7 1993); Estate of Richardson v. Commissioner, 89 T. C. 1193 (1987). Rather than continuing to expend resources in litigation that seemed likely
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