Pavel Dobra and Ana Dobra - Page 11

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               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 statute            







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