11
Lenz v. Commissioner, 101 T.C. 260, 265 (1993). We must rely on
the words of the statute as generally understood, for to do
otherwise would be to redraft the statute. United States v.
Locke, supra at 93, 95-96; Lenz v. Commissioner, supra at 265
(citing United States v. American Trucking Associations, Inc.,
supra at 542-543).
In interpreting any statue, we attempt to determine
Congress' intent in using the statutory language being construed.
United States v. American Trucking Associations, Inc., supra at
542; Helvering v. Stockholms Enskilda Bank, 293 U.S. 84, 93-94
(1934); General Signal Corp. & Subs. v. Commissioner, 103 T.C.
216, 240 (1994). Moreover, where the statute is ambiguous, we
may look to its legislative history and to the reason for its
enactment. United States v. American Trucking Associations,
Inc., supra at 543-544; U.S. Padding Corp. v. Commissioner, 88
T.C. 177, 184 (1987), affd. 865 F.2d 750 (6th Cir. 1989). In
addition, we may seek out any reliable evidence as to the
legislative purpose even where the statute is clear. United
States v. American Trucking Associations, Inc., supra; Centel
Communications Co. v. Commissioner, 92 T.C. 612, 628 (1989),
affd. 920 F.2d 1335 (7th Cir. 1990).
The relevant language in section 415(b)(5) includes "In the
case of an employee who has less than 10 years of service with
the employer". There is no dispute that the years of service
with the business organization that established and maintained
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