- 11 - Our work therefore begins with the text of section 131. As the Supreme Court has stated: “The task of resolving the dispute over the meaning of * * * [the statutory provision at issue] begins where all such inquiries must begin: with the language of the statute itself.” United States v. Ron Pair Enter., Inc., supra at 241 (citation omitted). Moreover, where the statute's language is plain, the language is also where the interpretative task should end. Id. Finally, it is a fundamental tenet of statutory interpretation that “the words of statutes--including revenue acts--should be interpreted where possible in their ordinary, everyday senses.” Crane v. Commissioner, supra at 6. We have recently relied on the common, ordinary, and plain meaning of words to interpret another aspect of section 131: the requirement that the foster individuals be “placed” in the foster home by a State or certain specified agencies. See section 131(b)(2); Micorescu v. Commissioner, T.C. Memo. 1998-398. It is in this spirit--and the spirit of Crane v. Commissioner, supra-- that we turn to the language of section 131 at issue here. Section 131(b)(1)(B) provides that a payment that is not a “difficulty of care payment” may be excluded only if it is “paid to the foster care provider for caring * * * in the foster care provider's home”. All the payments at issue were paid to petitioners. Therefore, under the plain language of the statutePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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