H&H Trim & Upholstery Co., Inc. - Page 6

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          expired.  Instead, we focus our attention on whether such                   
          interest is “excessive” as that term relates to interest and is             
          used in section 6404(a).                                                    
               According to respondent, interest that is assessed                     
          erroneously or illegally is excessive.  We agree.  But respondent           
          goes on to suggest that interest is excessive only if it is                 
          assessed erroneously or illegally.  Restricted in that manner, we           
          consider respondent’s construction of the term “excessive” to be            
          too narrow and otherwise objectionable as it renders the term               
          superfluous.  See Conn. Natl. Bank v. Germain, 503 U.S. 249, 253            
          (1992) (“courts should disfavor interpretations of statutes that            
          render language superfluous”).                                              
               Unless it leads to a result inconsistent with the overall              
          objective of a statute, a word used in a statute should be                  
          accorded its plain meaning.  See id.; United States v. Ron Pair             
          Enters., Inc., 489 U.S. 235, 242 (1989).  In this regard,                   
          respondent points out that petitioner’s position is based upon a            
          “fairness” standard, and respondent argues that the concept of              
          fairness is not contemplated by the term “excessive” as that term           
          relates to interest and is used in section 6404(a).  We disagree.           
          Webster’s Third New International Dictionary (1993) defines                 
          “excessive” as “whatever notably exceeds the reasonable, usual,             
          proper, necessary, just, or endurable”. (Emphasis added.)  It               
          further defines “just” to mean “equitable”, and “equitable” to              

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