In Botany Worsted Mills v. United States, 278 U.S. 282, (1929), the Supreme Court stated, "we think that Congress intended by the statute to prescribe the exclusive method by which tax cases could be compromised, ... and did not intend to intrust the final settlement of such matters to the informal action of subordinate officials in the Bureau. When a statute limits a thing to be done in a particular mode, it includes the negative of any other mode." Botany Worsted Mills, 278 U.S. at 288-89.