- 5 -
their service to their country. Section 112, in pertinent part,
provides that "Gross income does not include compensation
received for active service * * * for any month during any part
of which such member * * * served in a combat zone". Section 112
and the underlying regulations do not specifically address the
question of whether severance pay is excludable.
In construing a statute, we generally give effect to the
plain and ordinary meaning of its language. United States v.
Locke, 471 U.S. 84, 93, 95-96 (1985); United States v. American
Trucking Associations, 310 U.S. 534, 543 (1940). Words with a
fixed legal or judicially settled meaning, on the other hand,
generally must be presumed to have been used in that sense unless
such an interpretation would lead to absurd results. See United
States v. Merriam, 263 U.S. 179, 187 (1923); Lenz v.
Commissioner, 101 T.C. 260, 265 (1993). Our principal objective
in interpreting any statute is to determine Congress' intent in
using the statutory language being construed. United States v.
American Trucking Associations, supra at 542. When a statute is
ambiguous, we may look to its legislative history and the
purposes for its enactment. United States v. Ron Pair Enters.,
489 U.S. 235, 241 (1989). With respect to section 112, however,
there is a paucity of legislative history or discussion
concerning the legislative intent. See Bruinooge v. United
States, 213 Ct. Cl. 26, 550 F.2d 624, 627 (1977).
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