§233

Given the plain meaning of the relevant text and the historical setting laid out in detail in this Opinion, including caselaw, legislation, legislative history, and regulations, the Secretary’s adoption of a timely filing requirement and his attempted sub silentio overruling of contrary judicial and administrative precedents is unreasonable under Natl.

But we distinguished Anglo-American on its facts: “Here the question is whether the petitioner, by filing returns after the respondent made his determination of deficiencies * * *, relieved itself of the adverse condi- tion in which it was situated by reason of section 233.” Id.

The Board went on to distinguish its holding in Anglo-American Direct Tea Trading Co. v. Commissioner, supra, noting that Undoubtedly a taxpayer may litigate a determination of respondent on the basis of a return made by * * * [respondent]. But, a "return" filed by a taxpayer after such a return has been prepared and filed for him by respondent, under the circumstances existing here, is a nullity and does not comply with section 233, supra.

However, section 1401(c) provides that if there is an agreement in effect between the United States and a foreign country pursuant to section 233 of the Social Security Act, then self-employment income of an individual is exempt from American self-employment taxes to the extent that under the agreement the income is subject to tax under the Social Security system of the foreign country .

Predecessors to Section 882(c)(2) We trace section 882(c)(2) to its origin in section 233 of the Revenue Act of 1928.

The Board held that the filing of Form 1120H did not satisfy the requirements of section 233 of the Revenue Acts of 1928 and 1932 because the personal holding company surtax was a separate and distinct tax from the corporate income tax.

This authorization is now codified in section 233 of the Social Security Act, 42 U.S.C.

In the return that the Commissioner prepared for the taxpayer, the Commissioner disallowed deductions and credits pursuant to section 233 of the Revenue Act of 1934.28 The Commissioner then sent a notice of deficiency to the taxpayer based on that return.

In the return that the Commissioner prepared for the taxpayer, the Commissioner disallowed deductions and credits pursuant to section 233 of the Revenue Act of 1934.28 The Commissioner then sent a notice of deficiency to the taxpayer based on that return.

This authorization is now codified in section 233 ofthe Social Security Act, 42 U.S.C.

ed on the vessel or aircraft it touches at a port in the United States, ifthe employee is employed on and in connection with such vessel or aircraft when outside the United States, or (B) outside the United States by a citizen or resident ofthe United States as an employee for an American employer (as defined in subsection (h)), or (C) ifit is service, regardless ofwhere or by whom performed, which is designated as employment or recognized as equivalent to employment under an agreement entered i

The applicable version of section 6421(b) was amended by section 233(a) of the Energy Tax of 1978, Pub.