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not comport with the overall statutory design for obtaining the
benefit of the tax credit.
Petitioner relied heavily on the legislative history to
present its position. Petitioner contends that the legislative
history reveals Congress' intent that section 29 required that a
well meet the definition of a tight formation as utilized by FERC
in the NGPA section 503 administrative process. Although the
legislative history does contain some references to possibilities
for employing definitions established by FERC, those references
do not provide a basis for holding that the term "determination"
should be interpreted differently from its usual and established
meaning. Our examination of petitioner's argument leads us to
the same conclusion whether or not we consider the statute to be
ambiguous. In addition, we may seek out any reliable evidence as
to the legislative purpose even where the statute is clear.
United States v. American Trucking Associations, Inc., 310 U.S.
at 543-544; Centel Communications Co. v. Commissioner, 92 T.C.
612, 628 (1989), affd. 920 F.2d 1335 (7th Cir. 1990).
Congress enacted the NGPA in response to a generally growing
demand for natural gas and rising prices for energy in the late
seventies and early eighties. Williams Natural Gas Co. v. FERC,
872 F.2d at 440; ANR Pipeline Co. v. FERC, 870 F.2d 717, 719
(D.C. Cir. 1989). Producers of gas from tight formations could
qualify for incentive gas prices higher than the ceiling. These
incentive prices were valuable when uncontrolled gas prices were
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