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unambiguous, when the text's plain meaning defeats the statute's
stated purpose. As observed recently by the Court of Appeals for
the Ninth Circuit, the circuit in which an appeal of this case
lies:
We may not adopt a plain language interpretation of a
statutory provision that directly undercuts the clear
purpose of the statute. In Brooks v. Donovan, 699 F.2d
1010 (9th Cir. 1983), we refused to adopt a plain
language interpretation of a statute governing pension
funds. We reasoned that the "court must look beyond
the express language of a statute where a literal
interpretation 'would thwart the purpose of the overall
statutory scheme or lead to an absurd or futile
result.'" Brooks, 699 F.2d at 1011 (quoting
International Tel. & Tel. Corp. v. General Tel. & Elec.
Corp., 518 F.2d 913, 917-918 (9th Cir. 1975)). In
reaching our conclusion, we followed the Supreme
Court's approach in United States v. American Trucking
Associations, 310 U.S. 534, 60 S.Ct. 1059, 84 L.Ed.
1345 (1940). There the Court noted that "[w]hen [a
given] meaning has led to absurd results * * * this
Court has looked beyond the words to the purpose of the
act. Frequently, however, even when the plain meaning
did not produce absurd results but merely an
unreasonable one 'plainly at variance with the policy
of the legislation as a whole,' this Court has followed
that purpose, rather than the literal words." American
Trucking Associations, 310 U.S. at 543. * * *
[Albertson's, Inc. v. Commissioner, 42 F.3d 537, 545
(9th Cir. 1994), affg. 95 T.C. 415 (1990).]
Accordingly, in interpreting section 419A(f)(6), we look to
the statute as written by the legislators, and we consult the
statute's legislative history to learn its intended purpose and
to resolve ambiguity in the words used therein. Landgraf v. USI
Film Prods., 511 U.S. 244 (1994); Consumer Prod. Safety Commn. v.
GTE Sylvania, Inc., 447 U.S. 102, 108 (1980). Petitioners must
prove that the Prime Plan falls within the scope of section
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