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Because a return of capital or capital gain distribution is not a taxable dividend and no section 902 credit is allowable , the commenter argues that the pooling rules ( including the deficit carryback rules ) should not apply . Americans see democratic Taiwan as a part of communist China in the same way that Chechnya is part of the Russian Federation , and hence understand China 's legitimate ( indeed " sacred " ) right to invade it , the commentary argued . Hence , the commenter argues , since VER provisions under other Federal statutes have " historically protected unvested property rights in order to allow persons to perfect a vested property interest against the United States in its proprietary capacity , surely the same principles apply with more force to preserve superior vested rights against impairment when the United States acts , as it does under SMCRA , in its regulatory capacity . Selective public institutions , the trio argues , pursue twin missions : excellence in teaching and research , and service to all people of their states . In support of its position , the commenter argues that section 902 establishes rules that minimize double taxation by allowing a taxpayer to compute a deemed paid credit on a taxable dividend . In addition , the comment argued that sometimes a message is left on an answering machine and such a message should not be considered notice of an objection or other requirement . Otherwise , the commentator argued , the taxpayer would be forced to defend itself against an " unexpressed suspicion " based on information the taxpayer does not know the Customs Service has obtained and possibly has misinterpreted .