- 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...)
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