The Coca-Cola Company, and Includible Subsidiaries - Page 46

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          have a nonsensical result.  Exxon Corp. v. Commissioner, supra at           
          728.  We held further that the plain meaning rule does not                  
          preclude an examination behind the literal terms of the language            
          at issue if the lack of such an examination would compel an odd             
          result.  Exxon Corp. v. Commissioner, supra at 728 (citing Public           
          Citizen v. United States, 491 U.S. 440, 454 (1989)).                        
               We examined the legislative purpose and history of                     
          percentage depletion to ascertain whether and to what extent the            
          statutory framework was consistent with a literal interpretation            
          of the regulation at issue.  In so doing, we found that the plain           
          meaning of the regulation, as applied to the facts before us in             
          Exxon Corp., was against clear and longstanding congressional               
          intent.                                                                     
               Accordingly, we found that in computing allowance for                  
          percentage depletion, it was unreasonable for Exxon to determine            
          its 1979 "gross income from the property" for sales of natural              
          gas, after the gas was transported away from the wellhead, by the           
          method provided for in the last sentence of section 1.613-3(a),             
          Income Tax Regs., the representative market or field price                  
          method, where those prices resulted in a "gross income from the             
          property" five times Exxon's actual contract sales revenue.                 
               In the instant case, however, the only clear and consistent            
          congressional intent expressed with respect to the possession tax           
          credit regime is the encouragement of U.S. business operations in           
          U.S. possessions.  We do not find that the application of the               




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