- 7 - there; therefore, respondent argues that the Galena airport must be physically located on an Indian reservation “per se” in order to qualify for the IEC. We begin our analysis with the well-established rule that statutory construction begins with the language of the relevant statute. Consumer Prod. Safety Commn. v. GTE Sylvania, Inc., 447 U.S. 102, 108 (1980). Statutes are to be read so as to give effect to their plain and ordinary meaning unless to do so would produce absurd or futile results. United States v. Am. Trucking Associations, Inc., 310 U.S. 534, 543 (1940); see Tamarisk Country Club v. Commissioner, 84 T.C. 756, 761 (1985). We may use legislative history to clarify an ambiguous statute. Burlington N. R.R. v. Okla. Tax Commn., 481 U.S. 454, 461 (1987); City of New York v. Commissioner, 103 T.C. 481, 489 (1994), affd. 70 F.3d 142 (D.C. Cir. 1995). From the face of the statute, it is not clear what is meant by “within”. We therefore examine the legislative history to clarify the language. The House conference report accompanying the enactment of the section providing for the IEC referred to the IEC and to a related provision as “Tax incentives for businesses on Indian reservations.” H. Conf. Rept. 103-213, at 718 (1993) (emphasis added). Further, the conference report described the Senate amendment as follows: “Under the Senate amendment, businesses located on Indian reservations generally are allowed a creditPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011