- 10 - United States v. Am. Trucking Associations, Inc., 310 U.S. 534, 543-544 (1940); Venture Funding, Ltd. v. Commissioner, 110 T.C. 236, 241-242 (1998), affd. without published opinion 198 F.3d 248 (6th Cir. 1999); Trans City Life Ins. Co. v. Commissioner, 106 T.C. 274, 299 (1996). We apply the plain meaning of the words prescribed in the text unless we find that a word’s plain meaning is “inescapably ambiguous”. Venture Funding, Ltd. v. Commissioner, supra at 241-242; see Garcia v. United States, 469 U.S. 70, 76 n.3 (1984); see also Ex parte Collett, 337 U.S. 55 (1949). Where legislative “will has been expressed in reasonably plain terms, that language must ordinarily be regarded as conclusive.” Negonsott v. Samuels, 507 U.S. 99, 104 (1993). We look first to the text on the TJC. Section 38 allows each petitioner to credit against his tax the amount of a general business credit. In relevant part, section 38 provides: SEC. 38. GENERAL BUSINESS CREDIT. (a) Allowance of Credit.-–There shall be allowed as a credit against the tax imposed by this chapter for the taxable year an amount equal to the sum of–- (1) the business credit carryforwards carried to such taxable year, (2) the amount of the current year business credit, plus (3) the business credit carrybacks carried to such taxable year. (b) Current Year Business Credit.–-For purposes of this subpart, the amount of the current year businessPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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