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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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