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which is the most persuasive evidence of the statutory purpose.
United States v. American Trucking Associations, Inc., 310 U.S.
534, 542-543 (1940); Helvering v. Stockholms Enskilda Bank, 293
U.S. 84, 93-94 (1934); General Signal Corp. & Subs. v.
Commissioner, 103 T.C. 216, 240 (1994), supplemented by 104 T.C.
248 (1995). Ordinarily, the plain meaning of statutory language
is conclusive. United States v. Ron Pair Enters., Inc., 489 U.S.
235, 241-242 (1989).
Where a statute is silent or ambiguous, we look to
legislative history in an effort to ascertain congressional
intent. Burlington No. R.R. v. Oklahoma Tax Commn., 481 U.S.
454, 461 (1987); United States v. American Trucking Associations,
Inc., supra at 543-544; Peterson Marital Trust v. Commissioner,
102 T.C. 790, 799 (1994), affd. 78 F.3d 795 (2d Cir. 1996); U.S.
Padding Corp. v. Commissioner, 88 T.C. 177, 184 (1987), affd. 865
F.2d 750 (6th Cir. 1989). Even where the statutory language
appears to be clear, we are not precluded from consulting
legislative history. United States v. American Trucking
Associations, Inc., supra at 543-544. Nevertheless, our
authority to construe a statute is limited where the agency
charged with administering that statute has promulgated
regulations thereunder.
The limitation on our authority is found in the so-called
Chevron rule as stated in the following passage:
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