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as to override the plain meaning of the words used therein.
Huntsberry v. Commissioner, 83 T.C. 742, 747-748 (1984); see
Pallottini v. Commissioner, 90 T.C. 498, 503 (1988), and cases
there cited.
2. Section 72(e)(6)
Thus, we turn to the words of section 72(e)(6) that define
investment in the contract, as relevant herein, as "the aggregate
amount of * * * consideration paid for the contract * * * minus
the aggregate amount received under the contract". In the
instant case, petitioner invested, or paid, $82,900 for his IRA
with Loyola. Interpreted literally, section 72(e)(6) would treat
such amount as the "investment in the contract" because the
contribution was the consideration paid by petitioner for the
contract.
3. Legislative History
We find nothing ambiguous in the statute, and, accordingly,
feel controlled by its clear language. However, respondent
contends that a literal interpretation of section 72(e)(6)
reaches a result contrary to legislative intent. Thus, we have
examined the legislative histories of the 1974 enactment of
section 408(d)(1), its subsequent amendment in 1986, and the 1986
enactment of section 408(o). As discussed below, we are not
satisfied that the legislative history relied upon by respondent
rises to the level of unequivocal evidence of legislative purpose
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