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business are personal services." We cannot agree with GMC's
interpretation of the statute. First, this position would
nullify the prohibition against furnishing services contained in
section 4941(d)(1)(C), because almost any service would be a
"personal service" and fall within the exception. The statute
draws an explicit distinction between a "charge" for "furnishing
of goods, services, or facilities", see sec. 4941(d)(1)(C) and
(2)(C), and the payment of "compensation" "for personal
services", see sec. 4941(d)(1)(D) and (2)(E). GMC's argument
equating a charge for services with compensation for personal
services significantly erodes this distinction.
Second, GMC's interpretation of the term "personal services"
contravenes congressional intent, as expressed in the above
legislative history. We think it is clear that Congress intended
to prohibit self-dealing. Consequently, any exceptions to the
self-dealing transactions rules should be construed narrowly. We
therefore reject GMC's broad interpretation of the term "personal
services" and conclude that the janitorial services provided by
GMC do not meet the definition of "personal services". Accord-
ingly, we find that the payments made by the Museum to GMC
constitute "self-dealing" within the meaning of section
4941(d)(1)(C), and, as a consequence, GMC is liable for the self-
dealing excise tax under section 4941(a)(1).7
7Respondent asserts that, if GMC is liable for the self-
(continued...)
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