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Bank, 293 U.S. 84, 93 (1934). Subsequent to the Gould case, the
Supreme Court stated as follows:
We are not impressed by the argument that, as the
question here decided is doubtful, all doubts should be
resolved in favor of the taxpayer. It is the function
and duty of courts to resolve doubts. We know of no
reason why that function should be abdicated in a tax
case more than in any other. * * * [White v. United
States, 305 U.S. 281, 292 (1938).]
See United States v. Stewart, 311 U.S. 60, 71 (1940) ("those who
seek an exemption from a tax must rest it on more than a doubt or
ambiguity. Exemptions from taxation cannot rest upon mere
implications. * * * Exemptions from taxation are not to be
enlarged by implication if doubts are nicely balanced";
(citations and internal quotation marks omitted)).
Section 419A(f)(6) may be interpreted in light of all
pertinent evidence, textual and contextual, as to its meaning.
See Commissioner v. Soliman, 506 U.S. 168, 173 (1993); Crane v.
Commissioner, 331 U.S. 1, 6 (1947); Old Colony R. Co. v.
Commissioner, 284 U.S. 552, 560 (1932); see also Trans City Life
Ins. Co. v. Commissioner, 106 T.C. 274, 300 (1996). A statute
speaks for itself, and its legislative history will help us
discern the meaning of the words therein when the words are
"'inescapably ambiguous'". Garcia v. United States, 469 U.S. 70,
76 n.3 (1984)(quoting Schwegmann Bros. v. Calvert Distillers
Corp., 341 U.S. 384, 395 (1951) (Jackson, J., concurring)); see
also Ex parte Collett, 337 U.S. 55 (1949). Legislative history
will also help us to discern text, which is otherwise
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