United States v. Haggar Apparel Co., 526 U.S. 380, 15 (1999)

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394

UNITED STATES v. HAGGAR APPAREL CO.

Opinion of the Court

IV

A

The customs regulations may not be disregarded. Application of the Chevron framework is the beginning of the legal analysis. Like other courts, the Court of International Trade must, when appropriate, give regulations Chevron deference. Cf. Atlantic Mut. Ins. Co. v. Commissioner, 523 U. S. 382, 389 (1998) (when a term in the Internal Revenue Code is ambiguous, "the task that confronts us is to decide, not whether the Treasury regulation represents the best interpretation of the statute, but whether it represents a reasonable one"). The expertise of the Court of International Trade, somewhat like the expertise of the Tax Court, guides it in making complex determinations in a specialized area of the law; it is well positioned to evaluate customs regulations and their operation in light of the statutory mandate to determine if the preconditions for Chevron deference are present.

B

In addition to the applicability of the Chevron framework in general, we also granted certiorari on a second question, asking whether 19 CFR 10.16(c) (1998) met the preconditions for Chevron deference as a reasonable interpretation of the statutory phrase "operations incidental to the assembly process," Subheading 9802.00.80, HTSUS, 19 U. S. C. 1202, and Item 807.00, TSUS, 19 U. S. C. 1202 (1982 ed.). Because the Court of Appeals determined the Chevron framework was not applicable, it did not go on to consider whether the regulation ultimately warrants deference under that framework.

Respondent has made various arguments turning on the details and facts of its manufacturing process, including substantial arguments challenging the regulation's interpretation of the statutory language as well as the application of the regulation to the particular process and goods at issue

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