- 8 -8
utilized, unless such an interpretation will lead to absurd
results. See United States v. Locke, supra at 93, 95-96; United
States v. Merriam, 263 U.S. 179, 187 (1923); Lenz v.
Commissioner, 101 T.C. 260, 265 (1993) (citing United States v.
American Trucking Associations, Inc., supra at 542-543).
Our principal objective in interpreting any statute is to
determine Congress' intent in using the statutory language being
construed. United States v. American Trucking Associations,
Inc., supra at 542; Helvering v. Stockholms Enskilda Bank, 293
U.S. 84, 93-94 (1934); General Signal Corp. v. Commissioner, 103
T.C. 216, 240 (1994). In order to interpret Congress' intent
here, we must analyze section 29 and the NGPA section referenced
in section 29.
With these general principles in mind, we consider the
phrase "the determination of whether any gas is produced from
* * * a tight formation shall be made in accordance with section
503 of the Natural Gas Policy Act of 1978."6 Section 29 does not
6 This phrase appears in section 29(c) in the following
manner:
SEC. 29(c). Definition of Qualified Fuels.--For
purposes of this section--
(1) In general.--The term "qualified fuels"
means--
(A) oil produced from shale and tar sands,
(B) gas produced from--
(continued...)
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