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conclude that the Congress could not have meant what it
said. * * * [Id. at 213.]
Our reasoning in Reed also applies to the instant case.
C. Respondent’s Arguments Based on Statutory Text
Respondent contends that the title of section 107, “RENTAL
VALUE OF PARSONAGES”, shows that Congress intended to impose a
rental value limit under section 107(2). We disagree. It is
well settled that the heading of a section does not limit the
plain meaning of the text. See Brotherhood of Railroad Trainmen
v. Baltimore & O.R. Co., 331 U.S. 519, 528-529 (1947); Stanley
Works v. Commissioner, 87 T.C. 389, 419 (1986).
Respondent contends that to not impose a fair rental value
limit requires that we disregard the word “rental” in section
107(2). We disagree. Section 107(2) clearly is not limited to
payment of rent; on the contrary, it expressly applies to a
rental allowance “to the extent used * * * to rent or provide a
home.” (Emphasis added.) This includes home purchases. See sec.
1.107-1(c), Income Tax Regs.3
3 The dissent contends that the effect of our
interpretation of sec. 107(2) is to read the term “rental” out of
sec. 107(2). See dissent, infra pp. 16-17. We disagree, and we
believe our reading gives full effect to all of the words in sec.
107(2). First, sec. 107(2) specifically excludes not only the
cost of renting a home, but also the cost of providing a home.
Second, sec. 107(2) does not include language used in sec. 107(1)
that limits the amount of the sec. 107(2) exclusion to the rental
value of the residence; instead, sec. 107(2) requires that the
amount excluded be a rental allowance paid as compensation to the
minister and used by him or her to rent or provide a home.
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