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tight formation gas. Respondent's position relies solely on the
absence of a well-category determination under NGPA section 503
for the Hanson well.
Petitioner proposes several arguments, the main thrust of
which is that the use of the term "determination" in the statute
does not result in the requirement of a well-category
determination from FERC or under NGPA section 503. Petitioner
contends that the NGPA section 503 reference in section 29
provides a means to a substantive definition for tight formation
gas and was not intended to require an actual certification under
the NGPA. We agree with respondent.
Section 29 does not literally support the result petitioner
seeks. The use of the term "determination" and the reference in
section 29(c)(2) to NGPA section 503 would require a reading of
both sections to fully understand the requirements and meaning of
section 29. In construing a statute, courts seek the plain and
literal meaning of the language. United States v. Locke, 471
U.S. 84, 95-96 (1985); United States v. American Trucking
Associations, Inc., 310 U.S. 534, 543 (1940). In that regard,
words in revenue acts are generally interpreted in their
"ordinary, everyday senses". Commissioner v. Soliman, 506 U.S.
168, 174 (1993) (quoting Malat v. Riddell, 383 U.S. 569, 571
(1966) (quoting Crane v. Commissioner, 331 U.S. 1, 6 (1947))).
On the other hand, words with a recognized legal or
judicially settled meaning are generally presumed to have been so
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