George and Elam Campbell - Page 14

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            Petitioners essentially urge us to adopt a plain language                                    
            interpretation of section 72(e)(6) that would give petitioner a                              
            basis in his excess contribution.  Respondent contends, however,                             
            that a literal interpretation of section 72(e)(6) reaches a                                  
            result contrary to legislative intent.  Specifically, respondent                             
            contends that in amending section 408(d)(1), Congress intended to                            
            provide a basis for nondeductible contributions as contemplated                              
            by section 408(o), but did not intend to provide a basis for any                             
            contributions in excess of the section 408(o) limits.  Thus,                                 
            respondent urges us to look beyond the words of the statute to                               
            interpret its meaning.                                                                       
                  In construing section 72(e)(6), our task is to give effect                             
            to the intent of Congress, and we must begin with the statutory                              
            language, which is the most persuasive evidence of the statutory                             
            purpose.  United States v. American Trucking Associations, Inc.,                             
            310 U.S. 534, 542-543 (1940).  Ordinarily, the plain meaning of                              
            the statutory language is conclusive.  United States v. Ron Pair                             
            Enterprises Inc., 489 U.S. 235, 242 (1989).  Where a statute is                              
            silent or ambiguous, we may look to legislative history in an                                
            effort to ascertain congressional intent.  Burlington N. R.R. v.                             
            Oklahoma Tax Commn., 481 U.S. 454, 461 (1987); Griswold v United                             
            States, 59 F.3d 1571, 1575-1576 (11th Cir. 1995).  However, where                            
            a statute appears to be clear on its face, we require unequivocal                            
            evidence of legislative purpose before construing the statute so                             





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