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however, disregards “rental” as a modifier of “allowance” and
thereby renders superfluous a portion of the statute. While the
majority correctly emphasizes that section 107(2) is applicable
to a rental allowance used for payment either of rent or of other
expenses and purchases involved in providing a home, the majority
fails to address the requirement that the funds so used must, as
a threshold matter, qualify as the equivalent of a rental
allowance. The statute does not simply say that an allowance, or
even a housing allowance or a residence allowance, used to
provide a home may be excluded. Rather, the law states that
gross income does not include a rental allowance so used. The
majority’s interpretation effectively writes this term out of
section 107(2).
I am convinced that the choice and use of “rental” as a
modifier indicates that Congress envisioned an exclusion with a
correlation to rental value. I further believe that the title of
section 107, “RENTAL VALUE OF PARSONAGES”, offers additional
support for this conclusion. I do not dispute that, as the
majority observes, a section heading cannot limit the plain
meaning of the text, but here the title serves to reiterate the
importance and purpose of a word expressly included in the
provision.
I also feel that the reference in the text of section 107(2)
to the rental allowance as “part” of the minister’s compensation
is instructive. No one would seriously contend that the phrase
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