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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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