Joseph A. Morcos and Joann M. Morcos - Page 9

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          Their first argument is that section 280A is not applicable to              
          their rental of rooms in their personal residence because                   
          Congress intended the statute to apply only to vacation homes.              
          Petitioners base their argument on the explanations of the                  
          statute’s provisions in both the Senate and House reports which             
          focus on the limitation imposed on deductions attributable to the           
          rental of a vacation home.                                                  
               The starting point for construing the meaning of a statute             
          must be the language used by Congress.  Reiter v. Sonotone Corp.,           
          442 U.S. 330, 337 (1979).  We assume that the legislative purpose           
          is expressed by the ordinary meaning of the words used.  Richards           
          v. United States, 369 U.S. 1, 9 (1962).  Thus, absent a clearly             
          expressed legislative intention to the contrary, that language              
          must ordinarily be regarded as conclusive.  Am. Tobacco Co. v.              
          Patterson, 456 U.S. 63, 68 (1982); Consumer Prod. Safety Commn.             
          v. GTE Sylvania, Inc., 447 U.S. 102, 108 (1980).                            
               We have previously rejected petitioner’s argument, observing           
          that the plain language of section 280A contains no such                    
          limitation.  Russell v. Commissioner, T.C. Memo. 1994-96, affd.             
          without published opinion 76 F.3d 388 (9th Cir. 1995); Gilchrist            
          v. Commissioner, T.C. Memo. 1983-288.  Petitioners acknowledge              
          that section 280A is entitled “DISALLOWANCE OF CERTAIN EXPENSES             
          HOMES, ETC.” and that the language of the statute is not                    

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