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1987. The basis step-up is provided solely for
purposes of determining gain or loss upon sale or
exchange of the assets, not for purposes of determining
amounts of depreciation or for other purposes. The
basis adjustment is provided because the conferees
believe that such formerly tax-exempt organizations
should not be taxed on unrealized appreciation or
depreciation that accrued during the period the
organization was not generally subject to income
taxation. [H. Conf. Rept. 99-841 (Vol. II), at II-349-
II-350, 1986-3 C.B. (Vol. 4) 1, 349-350; emphasis
added.]
Petitioner argues that the statutory language is not
ambiguous and provides no limitation on the types of transactions
to which the basis step-up provision applies and therefore that
the limiting language in the legislative history is irrelevant.
In interpreting a statute, we look first to the language of
the statute, and we look only to legislative history to learn the
purpose of the statutory language or to resolve ambiguities in
the statutory language. Robinson v. Shell Oil Co., 519 U.S. 337,
340 (1997); Consumer Prod. Safety Commn. v. GTE Sylvania, Inc.,
447 U.S. 102, 108 (1980); Valansi v. Ashcroft, 278 F.3d 203, 209
(3d Cir. 2002); Fed. Home Loan Mortgage Corp. v. Commissioner,
121 T.C. 129, 134 (2003); Wells Fargo & Co. v. Commissioner, 120
T.C. 69, 89 (2003); Allen v. Commissioner, 118 T.C. 1, 7 (2002).
If the language of a statute is plain, clear, and
unambiguous, the statutory language is to be applied according to
its terms, United States v. Ron Pair Enters., Inc., 489 U.S. 235,
241 (1989); Burke v. Commissioner, 105 T.C. 41, 59 (1995), unless
a literal interpretation of the statutory language would lead to
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