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corporation' for a particular year is unaffected by subsequent
events." Respondent correctly points out that "Neither section
6038A, the regulations thereunder, nor the legislative history
contains any provision permitting a reporting corporation to
avoid the requirements and penalties of that section for a
particular year because of a subsequent change in stock
ownership." It is equally true, however, that section 6038A, the
regulations thereunder, and the legislative history make no
mention of the issue whatsoever. The issue is not whether
petitioner was a reporting corporation for the year in issue--it
was--but whether section 6038A(e)(3) applies for the year in
issue, an issue of first impression.
6. Discussion
We begin our analysis with the well-established rule that
statutory construction begins with the language of the relevant
statute. Consumer Prod. Safety Commn. v. GTE Sylvania, Inc., 447
U.S. 102, 108 (1980). Statutes are to be read so as to give
effect to their plain and ordinary meaning unless to do so would
produce absurd or futile results. United States v. American
Trucking Associations, Inc., 310 U.S. 534, 543-544 (1940); see
Tamarisk Country Club v. Commissioner, 84 T.C. 756, 761 (1985).
Moreover, where a statute is clear on its face, we require
unequivocal evidence of legislative purpose before construing the
statute so as to override the plain meaning of the words used
therein. Halpern v. Commissioner, 96 T.C. 895, 899 (1991);
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