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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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