Labels:book | reckoner | sky OCR: ambiguous 1958 Regulation. And the fewett majority's belief that the Commissioner had consistently interpreted both the Code and the Regulation regarding disclaimers was integral to its decision uphold the interpretation 10 the ambiguous 1958 Regulation. fact, documents that ere not before the Court ewett establish that the Commissioner had been consistent interpretations either Code the Regulation. fewett majority recognized, the Commissioner's interpretation of the Code regulation entitled C respect but only has been consistent 455 318; see also Rovan Cos. United States. 5 . 258. 63 {1981} (holding Treasury Depar tment eguiation invalid part Department's inconsistent interpretations published and private rulings since statute enactment 11 1935). The Court in Jewett did not have before th ...
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