U.S. Code
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Title 26
» Subtitle Subtitle F— Procedure and Administration › Chapter CHAPTER 80— GENERAL RULES › Subchapter Subchapter A— Application of Internal Revenue Laws
26 U.S.C. § 7806
Construction of title
(a) Cross referencesThe cross references in this title to other portions of the title, or other provisions of law, where the word “see” is used, are made only for convenience, and shall be given no legal effect.
(b) Arrangement and classificationNo inference, implication, or presumption of legislative construction shall be drawn or made by reason of the location or grouping of any particular section or provision or portion of this title, nor shall any table of contents, table of cross references, or similar outline, analysis, or descriptive matter relating to the contents of this title be given any legal effect. The preceding sentence also applies to the sidenotes and ancillary tables contained in the various prints of this Act before its enactment into law.
(Aug. 16, 1954, ch. 736, 68A Stat. 917.)Editorial NotesReferences in TextThis Act, referred to in subsec. (b), is act Aug. 16, 1954.
Notes of Decisions
United States v. Reorganized CF&I Fabricators of Utah, Inc., 518 U.S. 213 (1996).
· cites it 4× “14, 17-20; see also 26 U. S. C. § 7806 (b) ("No inference, implication, or presumption of legislative construction shall be drawn or made by reason of the location or grouping of any particular section or provision or portion of this title").”
Laing v. United States, 423 U.S. 161 (1976).
· cites it 2× “That approach is expressly *204 foreclosed, in any event, by § 7806 (b) of the 1954 Code, 26 U. S. C. § 7806 (b), providing that no inference shall be drawn by reason of the location or grouping of any particular section or portion of the tax title of the Code.”
United States v. Bisceglia, 420 U.S. 141 (1975).
· cites it 2× “26 U. S. C. § 7806 (b). The general mandate to canvass and inquire, now found in § 7601, is derived from § 3172 of the Revised Statutes of 1874.”
Alcoa, Inc. v. United States, 509 F.3d 173 (3d Cir. 2007).
“Evidently aware that this is a significant weakness in Alcoa’s theory, amicus Entergy Corporation argues that the restoration requirement is satisfied because the aim of CERCLA was “to restore to the public the income attributable to the producers’ environmental consumption.”
Commonwealth Ex Rel. Cuccinelli v. Sebelius, 728 F. Supp. 2d 768 (E.D. Va. 2010).
· cites it 2× “” 26 U.S.C. § 7806 (b). The Commonwealth emphasizes that the best evidence of congressional intent is the language chosen by that legislative body.”
Boeing Co. v. United States, 537 U.S. 437 (2003).
“861-8 (1979), the Secretary of the Treasury exercised his rulemaking authority under 26 U. S. C. § 7806 (a), which gives the Secretary general authority to “prescribe all needful rules and regulations for the enforcement” of the Internal Revenue Code.”
Florida Ex Rel. McCollum v. United States Dep't of Health & Human Servs., 716 F. Supp. 2d 1120 (N.D. Fla. 2010).
“In fact, while the penalty is placed under the “Excise Taxes” heading of the Code, at the same time Congress specifically exempted and divorced the penalty from all the traditional enforcement and collection methods used by the Internal Revenue Service, such as tax liens,…”
Grapevine Imports, Ltd. v. United States, 71 Fed. Cl. 324 (Fed. Cl. 2006).
“” However, section 7806(b) of the Code strictly instructs that the heading of a section is utterly without legal significance, stating: [n]o inference, implication, or presumption of legislative construction shall be drawn or made by reason of the location or grouping of any…”
Liberty Univ., Inc. v. Geithner, 753 F. Supp. 2d 611 (W.D. Va. 2010).
“26 U.S.C. § 7806 (b). Even more importantly, the assessments function as regulatory penalties—they encourage compliance with the Act by imposing a punitive expense on conduct that offends the Act.”
Washington Mut. Inc. v. United States, 636 F.3d 1207 (9th Cir. 2011).
“1978); see also 26 U.S.C. § 7806 (b). Secondly, the word "financial" does not exclude the concept of property, and the words of the section itself demonstrate that.”
Cinergy Corp. v. United States, 55 Fed. Cl. 489 (Fed. Cl. 2003).
“The court, however, does not attach independent significance to this title, see 26 U.S.C. § 7806 (b) (descriptive matter in Code not to be given legal effect); cf.”
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