- 8 - 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 IN CONNECTION WITH BUSINESS USE OF HOME, RENTAL OF VACATION HOMES, ETC.” and that the language of the statute is notPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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