Federal Home Loan Mortgage Corporation - Page 7

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               section 1016(a)(1)(relating to adjustments to basis of                 
               property).                                                             
          Respondent contends that petitioner cannot meet the requirements            
          of section 177(a) because it was not taxable in 1983 and 1984               
          when its expenditures were incurred.  Neither party cites court             
          opinions supporting its respective interpretations of section               
          177, and the issue appears to be one of first impression.                   
               It is a well-settled principle that tax deductions are a               
          matter of legislative grace, and taxpayers must show that they              
          come squarely within the terms of the law conferring the benefit            
          sought.  See Rule 142(a); INDOPCO, Inc. v. Commissioner, 503 U.S.           
          79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435,             
          440 (1934); Welch v. Helvering, 290 U.S. 111, 115 (1933); Wilkins           
          v. Commissioner, 120 T.C. 109, 112 (2003).  Further, in                     
          interpreting a statute, as in the instant cases, we start as                
          always with the language of the statute itself.  Consumer Prod.             
          Safety Commn. v. GTE Sylvania, Inc., 447 U.S. 102, 108 (1980);              
          Fed. Home Loan Mortgage Corp. v. Commissioner, 121 T.C. ___, ___            
          (Sept. 4, 2003).  We look to the legislative history primarily to           
          learn the purpose of the statute and to resolve any ambiguity in            
          the words contained in the text.  Fed. Home Loan Mortgage Corp.             
          v. Commissioner, supra at ___; Wells Fargo & Co. v. Commissioner,           
          120 T.C. 69, 89 (2003); Allen v. Commissioner, 118 T.C. 1, 7                
          (2002).  If the language of the statute is plain, clear, and                
          unambiguous, we generally apply it according to its terms.                  





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