§01

* * * Also, see section 86(f)(3), which provides that "any social security benefit shall be treated as an amount rece ved as a pension or annuity." The term "compen ation" is further defined in section 1.219-1(c)(1), Income Tax Regs., as follows: (1) Compensation.--Forpurposes ofthis section, the term "compensation" means wages, salaries, professional

6664-2(d), Income Tax Regs . , would eviscerate the entire regulatory venture . I do not believe that in.the absence of sec. 1.6664-2(d), Income Tax Regs . , sec . 1. 6664 -2 (c) (1) , Income Tax Regs . , or for that matter, any other provision of -sec. 01.6664-2, Income Tax Regs:, can stand on its own since, as explained above, sec. 1.6664-2(d), Income (continued. . . ) I agree with Judge Gustafson, that "section 6664 (a) (1) (A) is not -ambiguous, and under the Supreme Court' s Chevron analysi