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unreimbursed employee expenses in dispute. Respondent calculated
the $3,485 amount by applying a ratio of the number of days
petitioner was under contract with Texas Instruments in 1993, up
to, and including, March 10, 1993, compared to the total number
of days petitioner was under contract at Texas Instruments in
1993 (69/351), multiplied by the parties’ stipulated 1993 job-
related travel expenses of $17,727.
We find the statutory language of section 162(a) clear.
When interpreting statutes, the function of courts is to construe
the language of the statute so as to give effect to the intent of
Congress. See U.S. Padding Corp. v. Commissioner, 88 T.C. 177,
184 (1987), affd. 865 F.2d 750 (6th Cir. 1989). Where possible,
statutes and revenue acts should be interpreted in their ordinary
everyday sense. See Crane v. Commissioner, 331 U.S. 1, 6 (1947).
The amended language of section 162(a) clearly states that a
"taxpayer shall not be treated as being temporarily away from
home during any period of employment if such period exceeds 1
year." (Emphasis added.) Additionally, the amendment clearly
"[applies] to costs paid or incurred after December 31, 1992."
EPA 1992, sec. 1938(b), 106 Stat. 3033 (emphasis added.)
On March 10, 1993, petitioner had been employed by Texas
Instruments for 365 days. At that time, petitioner knew that his
contract with Texas Instruments would be extended for an
additional period of time and no longer had a realistic
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