§325

in meaning ofthe language ofa treaty controls unless its effect is contrary to the intent or expectations ofthe signatories. Sanchez-Llamas v. Oregon, 548 U.S. 331, 346 (2006) (citing 1 Restatement (Third) ofForeign Relations Law ofthe United States sec. 325(1) (1986)); Sumitomo Shoji Am., Inc., 457 U.S. at 180; Amaral v. Commissioner, 90 T.C. 802, 812 (1988). Because treaties are contracts between sovereigns, we construe them more liberally than private agreements to give effect to the signator

325F.68-325F.70 (West 2014), that stops companies from committing any "fraud, fàlse pretense, false promise, misrepresentation, misleading statement or deceptive practice;" and (cid:16)042the Federal Truth In Lending Act, see generally 15 U.S.C. secs. 1601, which has as its goal to "assure a meaningful disclosure ofcredit terms * * * and to pr

eted in accordance with the ordinary meaning of its terms, consistentlywith their context and the agreement's object and purpose. Sanchez-Llamas v. Oregon, 548 U.S. 331, 346 (quoting 1 Restatement (Third) of Foreign Relations Law ofthe United States sec. 325(1) (1986)). Treaties are con- tracts between sovereigns and, as such, should be construed to give effect to the signatories' intent. United States v. Stuart, 489 U.S. 353, 365-366 (1989). Because treaties are construedmore liberally than pri

ed in accordance with the ordinary meaning of its terms, consistently with their context and the agreement’s object and purpose. Sanchez-Llamas v. Oregon, 548 U.S. 331, 346 (quoting 1 Restatement (Third) of Foreign Relations Law of the United States sec. 325(1) (1986)). Treaties are contracts between sovereigns and, as such, should be construed to give effect to the signatories’ intent. United States v. Stuart, 489 U.S. 353, 365-366 (1989). Because treaties are construed more liberally than priv

ssment of the tax (or, if earlier, the date of the payment of the tax). For 1980 and 1981, the fraud addition to tax is provided for in sec. 6653(b), the first sentence of which is the same as the above-quoted sec. 6653(b)(1). Par. (2) was added by sec. 325(a) of the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. 97-248, 96 Stat. 324, 616, and was effective for taxes the payment of which (determined without regard to any extension) is due after Sept. 3, 1982. In the instant case, par.

ssment of the tax (or, if earlier, the date of the payment of the tax). For 1980 and 1981, the fraud addition to tax is provided for in sec. 6653(b), the first sentence of which is the same as the above-quoted sec. 6653(b)(1). Par. (2) was added by sec. 325(a) of the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. 97-248, 96 Stat. 324, 616, and was effective for taxes the payment of which (determined without regard to any extension) is due after Sept. 3, 1982. In the instant case, par.

o petitioner's 1980 and 1981 taxable years, sec. 6653(b) provides: "If any part of any underpayment * * * of tax required to be shown on a return is due to fraud, there shall be added to the tax an amount equal to 50 percent of the underpayment." 23 Sec. 325(a) of the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. 97-248, 96 Stat. 616-617, amended sec. 6653(b) effective for taxes the last day prescribed by law for the payment of which, without regard to extensions, was after Sept. 3,

the underpayment was due to fraud), in order to sustain her allegations under: (1) Section 6653(b)(1) for petitioners' - 20 - 1985 taxable years,6 (2) section 6653(b)(1)(A) for petitioners' 1986 taxable years and the Lees' 1987 taxable year,7 and 6 Sec. 325(a) of the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. 97-248, 96 Stat. 616-617, amended sec. 6653(b) effective for taxes the last day prescribed by law for the payment of which, without regard to extensions, was after Sept. 3, 1

the underpayment was due to fraud), in order to sustain her allegations under: (1) Section 6653(b)(1) for petitioners' - 20 - 1985 taxable years,6 (2) section 6653(b)(1)(A) for petitioners' 1986 taxable years and the Lees' 1987 taxable year,7 and 6 Sec. 325(a) of the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. 97-248, 96 Stat. 616-617, amended sec. 6653(b) effective for taxes the last day prescribed by law for the payment of which, without regard to extensions, was after Sept. 3, 1

325(a), 96 Stat. 324, 616. The TEFRA version of sec. 6653(b) modified the calculation of the fraud addition. The statutory notices with respect to the periods ending Dec. 31, 1982, and Dec. 31, 1984 (after the effective date of TEFRA), do not expressly indicate whether respondent used the post-TEFRA formulation. Since the parties have settled