- 33 -
Andrews, 534 U.S. 19, 29 (2001) (rejecting Andrews’s “attempt to
generate some role for the express exception [in the statute]
independent of that [which would be] filled by” the rule of
general application she asked the Court to read into the statute);
Anderson v. Commissioner, 123 T.C. 219, 236-237 (2004) (rejecting
an interpretation of section 3121(b)(20) that would have
effectively denied its beneficial effects to most, if not all,
small fishing boat owners who are the intended beneficiaries of
the provision).
Expanding the reach of section 71(b)(1)(D) to the extent
suggested by the worst case scenario approach also runs contrary
to the maxim that a specific provision controls over a general
one, particularly when the two are interrelated and closely
situated in the statute. E.g., HCSC-Laundry v. United States, 450
U.S. 1, 6 (1981) (analyzing section 501(c)(3) and (e)). Inasmuch
as section 71(c)(1), but not section 71(b)(1)(D), specifically
addresses child support, the foregoing rule of construction
militates against an interpretation of section 71(b)(1)(D) which,
contrary to the specific designation principle of section
71(c)(1), invariably has the effect of converting undesignated
support into child support.
b. Legislative History of the 1984 Act
Notwithstanding the foregoing, the intent of the drafters is
27(...continued)
Pennsylvania’s child support guidelines).
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