- 6 - 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” toPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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