in the same place
or with the same person or group". Finally, remain can mean "to
continue unchanged in form, condition, status, or quantity",
"continue to be", or "stand".
Respondent asserts that the word "remaining" is used
throughout the Internal Revenue Code "almost exclusively" to mean
that portion which is left over from the whole. We agree that the
word "remaining" often refers to what is left; i.e., the remaining
amount; e.g., sections 72(s)(1)(A), 74(c)(2), 170(l), 172(f)(5),
401(a)(9)(B)(i)(II), 414(k)(2), 671, 864(f)(1)(C), and 865(c)(1)(B)
refer to "the remaining portion",10 and sections 169(a) and 194(a)
See also, sec. 25(a)(1)(B) ("the remaining principal"); sec. 6861(f) ("any remaining portion"); sec. 451(h)(2)(A) ("a qualified prize (or remaining portion thereof)"); sec. 148(f)(3) ("the remaining balance"); sec. 6340(c)(3) ("the remaining balance of such liability"); sec. 263A(d)(2)(B)(ii) ("any part of the remaining equity interest"); sec. 408A(d)(3)(E)(ii) ("all remaining amounts""); sec. 904(f)(3)(A)(i) ("the remaining amount"); sec. 996(a)(2) ("the remaining 1/17th of such amount"); sec. 565(f)(1) ("all the remaining earnings and profits"); section 732(c)(1)(B) ("to the extent of any basis remaining after the allocation", "such remaining basis"); sec. 1250(d)(4)(D)(ii) ("the remaining gain not recognized on the transaction"); sec. 4254(a)(2) ("the remaining items not included in any such group"); sec. 1082(a)(2)(G) ("all other remaining property"); sec. 1250(f)(3)(C) ("the remaining property"); sec. 1272(a)(6)(A)(i) ("all remaining payments"); sec. 4943(c)(1) ("the remaining holdings"); sec. 7507(c)(3) ("to the extent of the remaining assets"); secs. 47(c)(2)(B)(vi), 147(f)(2)(E) ("the remaining term"); sec. 42(j)(6)(B) ("the remaining compliance period"); sec. 412(b)(4) ("the remaining amortization period"); sec. 192(c)(1)(B)(i) ("the average remaining (continued...) - 31 -
refer to "the number of months * * * remaining in the period".11
(...continued) working life"); sec. 418B(d)(3)(C)(ii) ("the average of the remaining expected lives"); sec. 404(a)(1)(A)(ii) ("the remaining future service"); sec. 447(f)(3),(i)(5)(C) ("the remaining taxable years"); sec. 7702A(c)(3)(B)(ii) ("the remaining period"); secs. 1274(d)(1)(C)(i), 9501(c)(3), 9507(d)(3)(C), 9509(d)(3)(C) ("remaining periods to maturity"); sec. 542(d)(1)(B) ("the remaining maturity"); sec. 4980(d)(5)(C) ("the remaining participants"); sec. 5123(d)(3) ("remaining partners"); sec. 7444(d) ("the remaining judges"); sec. 7448(h) ("any remaining dependent child or children"); sec. 8002(c)(12) ("the remaining members"); sec. 7702B(d)(3)(B) ("any remaining limitation"). See, e.g., sec. 667(b)(1)(C) ("each of the 3 taxable years remaining after the application of subparagraph (B)"); sec. 667(d)(1)(D) ("any of the three taxable years remaining after application of subsection (b)(1)(B)"); sec. 178(a)(b) ("the period of the term of the lease remaining on the date of its acquisition"); sec. 401(h)(5) ("any amount remaining in such separate account"); sec. 832(e)(5)(A) ("the amount (if any) remaining which was added to the account", "any amounts remaining in such reserve", "the entire amount remaining in such account"); sec. 847(6)(A) ("the entire amount remaining in such special loss discount account"); sec. 6342(a)(2),(3) ("the amount remaining after applying paragraph (1)", "The amount, if any, remaining after applying paragraphs (1) and (2)"); sec. 7652(b)(3)(B) ("Any amounts remaining"); section 732(c)(1)(B) ("to the extent of any basis remaining after the allocation"); sec. 7518(f)(4) ("Any amount of a withdrawal remaining after the application of the preceding sentence"); sec. 404(a)(3)(B) ("total current and accumulated earnings or profits remaining