10
We begin with the presumption that respondent's
determination is correct, and petitioners have the burden of
proving otherwise. Rule 142(a); Welch v. Helvering, 290 U.S.
111, 115 (1933); Dellacroce v. Commissioner, 83 T.C. 269, 279-280
(1984). Deductions and credits are a matter of legislative
grace, and petitioners bear the burden of proving entitlement to
any deduction or credit claimed on their returns. INDOPCO, Inc.
v. Commissioner, 503 U.S. 79 (1992); New Colonial Ice Co. v.
Helvering, 292 U.S. 435, 440 (1934).
In construing a statute, courts generally seek the plain and
literal meaning of its language. United States v. Locke, 471
U.S. 84, 93, 95-96 (1985); United States v. American Trucking
Associations, Inc., 310 U.S. 534, 543 (1940). For that purpose,
courts generally assume that Congress uses common words in their
popular meaning. Commissioner v. Groetzinger, 480 U.S. 23, 28
(1987); see also Addison v. Holly Hill Fruit Prods., Inc., 322
U.S. 607, 618 (1944). Moreover, words in a revenue act
generally are 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))).
Words with a fixed legal or judicially settled meaning, on
the other hand, generally must be presumed to have been used in
that sense, unless such an interpretation will lead to absurd
results. See United States v. Merriam, 263 U.S. 179, 187 (1923);
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