- 9 - Normally, we look to the plain language of a statute to interpret its meaning. See Consumer Prod. Safety Commn. v. GTE Sylvania, Inc., 447 U.S. 102, 108 (1980); Union Carbide Foreign Sales Corp. v. Commissioner, 115 T.C. 423, 430 (2000). When a statute is clear on its face, we require unequivocal evidence of legislative purpose before interpreting the statute to override the plain meaning of the words used therein. See Hirasuna v. Commissioner, 89 T.C. 1216, 1224 (1987); Huntsberry v. Commissioner, 83 T.C. 742, 747-748 (1984). The legislative history of section 197 contains no evidence that Congress intended a purchase of stock to be excluded from the meaning of the term “acquisition” simply because the purchase occurred in the form of a redemption. The term “acquisition” is defined as “The gaining of possession or control over something” and “Something acquired”. Black’s Law Dictionary 24 (7th ed. 1999). The term “redemption” is defined as “The act or an instance of reclaiming or regaining possession by paying a specific price.”8 Id. at 1282. Redemption, in the context of securities, is defined as “The reacquisition of a security by the issuer.”9 Id. In the instant 8See Boyle v. Commissioner, 14 T.C. 1382, 1390 n.7 (1950), affd. 187 F.2d 557 (3d Cir. 1951), for a detailed discussion of the origin and meaning of the term “redemption”. 9We note that under sec. 317(b) (relating to corporate distributions and adjustments), stock is treated as redeemed by a (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011