Frontier Chevrolet Co. - Page 9




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               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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