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Budget Reconciliation Act of 1990, Pub. L. 101-508, sec.
11111(a), 104 Stat. 1388, 1388-408 (the act that enacted the
"qualifying child" test). Respondent then contends that if a
child satisfies the relationship, abode, and age requirements
found in section 32(c)(3)(A)(i), (ii), and (iii), the child is a
qualifying child. Respondent claims the identification
requirement found in section 32(c)(3)(A)(iv) is merely a
requirement to report the name, age, and Taxpayer Identification
Number of an individual who is otherwise a qualifying child. On
brief, respondent argues that Congress imposed the identification
requirement simply to ease administration of the law and reduce
respondent's administrative burden. See H. Conf. Rept. 101-964,
at 1037 (1990), 1991-2 C.B. 560, 564. Yet, the legislative
history cited above shows that there are four requirements to
meet the definition of a qualifying child. In fact, respondent
so admits on brief.
The starting point for interpreting a statute is the
language of the statute itself. Consumer Product Safety Comm'n
v. GTE Sylvania, Inc., 447 U.S. 102, 108 (1980). If the language
of the statute is plain, clear, and unambiguous, "'the sole
function of the courts is to enforce it according to its terms.'"
United States v. Ron Pair Enterprises, Inc., 489 U.S. 235, 241
(1989) (quoting Caminetti v. United States, 242 U.S. 470, 485
(1917)). Thus, as long as the statutory language is clear and
unambiguous, there generally is no need for courts to inquire
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