- 9 -
United States v. American Trucking Associations, Inc., 310 U.S.
534, 542-543 (1940); Hospital Corp. of Am. v. Commissioner, 107
T.C. 116, 128 (1996). The plain meaning of statutory language
ordinarily is conclusive. United States v. Ron Pair Enters.,
Inc., 489 U.S. 235, 241-242 (1989). If a statute is silent or
ambiguous, we turn to legislative history to ascertain
congressional intent. Burlington N. R.R. v. Oklahoma Tax Commn.,
481 U.S. 454, 461 (1987); Peterson Marital Trust v. Commissioner,
102 T.C. 790, 799 (1994), affd. 78 F.3d 795 (2d Cir. 1996).9
Section 6224(c)(2) requires that the settlement agreement
forming the basis for the request for consistent settlement terms
must be "a settlement agreement * * * with respect to partnership
items". The statute otherwise imposes no conditions upon those
settlement agreements that may be subject to requests for
consistent settlement terms. On the other hand, the parameters
of what constitutes a settlement agreement for purposes of
section 6224(c)(2) are not statutorily defined. Reference to the
Spartan legislative history on settlement agreements in TEFRA
proceedings is unilluminating, as the conference report evinces
9
Even where the statutory language appears to be clear
we are not precluded from consulting legislative history. United
States v. American Trucking Associations, Inc., 310 U.S. 534,
543-544 (1940); Hospital Corp. of Am. v. Commissioner, 107 T.C.
116, 129 (1996).
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