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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 business
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