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B. Respondent’s Argument
Respondent maintains that the family aggregation rule
applies solely with reference to living individuals. Under that
view, inasmuch as none of the parents and grandparents of the
Garber brothers was alive at the commencement of the 3-year
testing period immediately preceding the 1998 transaction, from
that point forward there was no individual, within the meaning of
section 382(l)(3)(A)(i), whose family members (as described in
section 318(a)(1)) included both Charles and Kenneth. It
follows, respondent argues, that Charles and Kenneth are not
treated as one individual for purposes of section 382 and that
the 1998 transaction resulted in an ownership change with respect
to petitioner under section 382.
III. Analysis
A. General Principles of Statutory Construction
As a general matter, if the language of a statute is
unambiguous on its face, we apply the statute in accordance with
its terms, without resort to extrinsic interpretive aids such as
legislative history. E.g., Fed. Home Loan Mortgage Corp. v.
Commissioner, 121 T.C. 129, 134 (2003) (citing United States v.
Ron Pair Enters., Inc., 489 U.S. 235, 241 (1989)). Accordingly,
our initial inquiry is whether the language of section
382(l)(3)(A)(i) is so plain as to permit only one reasonable
interpretation insofar as the question presented in this case is
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