Contents
Contents Contents
APPENDIX Athis history is in congressional committee reports. Reports from committees inthe House of Representatives are cited as “H. Rep. No.” (see, e.g., Chapter 1, note17); reports from committees in the Senate are cited as “S. Rep. No.” (see, e.g.,Chapter 3, note 130); conference committee reports are cited as “H. Rep. No.”(see, e.g., id.). Transcripts of the debate on legislation, formal statements, andother items are printed in the Congressional Record (Cong. Rec.). The CongressionalRecord is published every day one of the houses of Congress is in session and iscited as “[number] Cong. Rec. [number] (daily ed., [date of issue]).” The firstnumber is the annual volume number, the second number is the page in the dailyedition on which the item begins. Periodically, the daily editions of the CongressionalRecord are republished as a hardbound book and are cited as “[number]Cong. Rec. [number] ([year]).” As before, the first number is the annual volumenumber and the second is the beginning page number. The bound version of theCongressional Record then becomes the publication that contains the permanentcitation for the item.A Congress sits for two years, each of which is termed a session. Each Congressis sequentially numbered. For example, the 109th Congress will meet duringthe calendar years 2005–2006. A legislative development that took place in2005 is referenced as occurring during the 109th Congress, 1st Session (109thCong., 1st Sess. (2005)).A bill introduced in the House of Representatives or Senate during a particularCongress is given a sequential number in each house. For example, the1,000th bill introduced in the House of Representatives in 2005 is cited as “H.R.1000, 109th Cong., 1st Sess. (2005)”; the 500th bill introduced in the Senate in2005 is cited as “S. 500, 109th Cong., 1st Sess. (2005).”Executive BranchA function of the executive branch in the United States is to administer andenforce the laws enacted by Congress. This executive function is performed bydepartments and agencies, and “independent” regulatory commissions (such asthe Federal Trade Commission or the Securities and Exchange Commission).One of these functions is the promulgation of regulations, which are publishedby the U.S. government in the Code of Federal Regulations (C.F.R.). When adopted,regulations are printed in the Federal Register (Fed. Reg.). The federal tax laws areadministered and enforced by the Department of the Treasury.One of the ways in which the Department of the Treasury executes thesefunctions is by the promulgation of regulations (Treas. Reg. or simply Reg.),which are designed to interpret and amplify the related statute (see, e.g., Chapter1, note 25). These regulations (like rules made by other departments, agencies,and commissions) have the force of law, unless they are overly broad inrelation to the accompanying statute or are unconstitutional, in which case theycan be rendered void by a court.Within the Department of the Treasury is the Internal Revenue Service (IRS).The IRS is, among its many roles, a tax-collecting agency. The IRS, though headquarteredin Washington, D.C. (its “National Office”), has regional and fieldoffices throughout the country. 642
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- Page 1344: APPENDIX BSection 2106(a)(2)(A)—e
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APPENDIX Athis history is in congressional committee reports. Reports from committees inthe House of Representatives are cited as “H. Rep. No.” (see, e.g., Chapter 1, note17); reports from committees in the Senate are cited as “S. Rep. No.” (see, e.g.,Chapter 3, note 130); conference committee reports are cited as “H. Rep. No.”(see, e.g., id.). Transcripts of the debate on legislation, formal statements, andother items are printed in the Congressional Record (Cong. Rec.). The CongressionalRecord is published every day one of the houses of Congress is in session and iscited as “[number] Cong. Rec. [number] (daily ed., [date of issue]).” The firstnumber is the annual volume number, the second number is the page in the dailyedition on which the item begins. Periodically, the daily editions of the CongressionalRecord are republished as a hardbound book and are cited as “[number]Cong. Rec. [number] ([year]).” As before, the first number is the annual volumenumber and the second is the beginning page number. The bound version of theCongressional Record then becomes the publication that contains the permanentcitation for the item.A Congress sits for two years, each of which is termed a session. Each Congressis sequentially numbered. For example, the 109th Congress will meet duringthe calendar years 2005–2006. A legislative development that took place in2005 is referenced as occurring during the 109th Congress, 1st Session (109thCong., 1st Sess. (2005)).A bill introduced in the House of Representatives or Senate during a particularCongress is given a sequential number in each house. For example, the1,000th bill introduced in the House of Representatives in 2005 is cited as “H.R.1000, 109th Cong., 1st Sess. (2005)”; the 500th bill introduced in the Senate in2005 is cited as “S. 500, 109th Cong., 1st Sess. (2005).”Executive BranchA function of the executive branch in the United States is to administer andenforce the laws enacted by Congress. This executive function is performed bydepartments and agencies, and “independent” regulatory commissions (such asthe Federal Trade Commission or the Securities and Exchange Commission).One of these functions is the promulgation of regulations, which are publishedby the U.S. government in the Code of Federal Regulations (C.F.R.). When adopted,regulations are printed in the Federal Register (Fed. Reg.). The federal tax laws areadministered and enforced by the Department of the Treasury.One of the ways in which the Department of the Treasury executes thesefunctions is by the promulgation of regulations (Treas. Reg. or simply Reg.),which are designed to interpret and amplify the related statute (see, e.g., Chapter1, note 25). These regulations (like rules made by other departments, agencies,and commissions) have the force of law, unless they are overly broad inrelation to the accompanying statute or are unconstitutional, in which case theycan be rendered void by a court.Within the Department of the Treasury is the Internal Revenue Service (IRS).The IRS is, among its many roles, a tax-collecting agency. The IRS, though headquarteredin Washington, D.C. (its “National Office”), has regional and fieldoffices throughout the country. 642