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such as a partnership. Section 1056 has not previously been
considered by any court. Significantly, although regulations are
mandated in the statute, since its enactment 20 years ago, none
have been issued. The absence of regulations (interpretative or
legislative), however, does not limit our ability to interpret
the statute and decide the issues presented in this case.
In construing a statute, we generally give effect to the
plain and ordinary meaning of its language. United States v.
Locke, 471 U.S. 84, 93, 95-96 (1985); United States v. American
Trucking Associations, Inc., 310 U.S. 534, 543 (1940). Words
with a fixed legal or judicially settled meaning, on the other
hand, generally must be presumed to have been used in that sense
unless such an interpretation would lead to absurd results. See
United States v. Merriam, 263 U.S. 179, 187 (1923); Lenz v.
Commissioner, 101 T.C. 260, 265 (1993). 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; General
Signal Corp. & Subs. v. Commissioner, 103 T.C. 216, 240 (1994),
supplemented by 104 T.C. 248 (1995). When a statute is
ambiguous, we may look to its legislative history and the
purposes for its enactment. United States v. Ron Pair Enters.,
Inc., 489 U.S. 235, 241 (1989); Peterson Marital Trust v.
Commissioner, 102 T.C. 790, 799 (1994), affd. 78 F.3d 795 (2d
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