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wage expense. Petitioners contend that disallowing part of the
deduction may place taxpayers in a worse position by electing the
TJC than by not making the election. We disagree that our
holding herein frustrates congressional intent. The primary way
to foster congressional intent is to apply, as we do here, the
plain meaning of the statute as written. In this regard, the
Supreme Court has stated: “courts must presume that a
legislature says in a statute what it means and means in a
statute what it says there.” Conn. Natl. Bank v. Germain,
503 U.S. 249, 253-254 (1992) (citations and quotation marks
omitted).
We sustain respondent’s determination on this issue. In so
doing, we have considered all arguments made by the parties and
have rejected those arguments not discussed herein as without
merit. Accordingly,
Decisions will be entered for
respondent in docket Nos. 1287-00,
1288-00, 1289-00, 1290-00, 1293-00, and
1618-00, and decisions will be entered
under Rule 155 in docket Nos. 1291-00
and 1292-00.
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