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Plain Meaning
The starting point for the interpretation of a statute is
the language itself. Consumer Prod. Safety Commn. v. GTE
Sylvania, Inc., 447 U.S. 102, 108 (1980); Dyer v. United States,
832 F.2d 1062, 1066 (9th Cir. 1987). If the language of the
statute is plain, clear, and unambiguous, "'the sole function of
the courts is to enforce it according to its terms.'" United
States v. Ron Pair Enters., Inc., 489 U.S. 235, 241 (1989)
(quoting Caminetti v. United States, 242 U.S. 470, 485 (1917)).
The Court must assume that the legislative purpose of the
statute is expressed in the ordinary meaning of the words used.
American Tobacco Co. v. Patterson, 456 U.S. 63, 68 (1982);
Richards v. United States, 369 U.S. 1, 9 (1962); Florida Hosp.
Trust Fund v. Commissioner, 103 T.C. 140, 152 (1994), affd. 71
F.3d 808 (11th Cir. 1996). Where there is a conflict in
inferences between the language of the statute and the
legislative history, the language of the statute generally
prevails. In re Stringer, 847 F.2d 549, 551 (9th Cir. 1988);
Huntsberry v. Commissioner, 83 T.C. 742, 747-748 (1984).
The common meaning of the verb "to place" is:
1: to distribute in an orderly manner: ARRANGE 2 a: to
put in or as if in a particular place: SET b: to
present for consideration (a question placed before the
group) c: to put in a particular state (~ a performer
under contract) d: to direct to a desired spot * * * 4:
to find a place (as a home or employment) for * * * *
[Webster's Ninth New Collegiate Dictionary 897 (1990).]
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