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however, specifically define “equipment” or address the treatment
of expenses for computers. Notice 97-60, supra. Moreover, the
authoritative sources of Federal tax law are statutes,
regulations, and judicial case law and not informal Internal
Revenue Service sources. See Zimmerman v. Commissioner, 71 T.C.
367, 371 (1978), affd. without published opinion 614 F.2d 1294
(2d Cir. 1979); Green v. Commissioner, 59 T.C. 456, 458 (1972).
Thus, petitioners’ reliance on Notice 97-60 is misplaced.
Petitioners’ contention that a computer is included under
the meaning of the word equipment warrants consideration, as the
absence of detail from a statutory text, or Congressional
reluctance to legislate for all possible future situations, does
not mean that Congress thereby intended to adopt a policy
intolerant of adaptive interpretation. Zabolotny v.
Commissioner, 97 T.C. 385, 412 (1991) (citing Deluxe Corp. v.
United States, 885 F.2d 848, 850-851 (Fed. Cir. 1989)), affd. in
part and revd. in part 7 F.3d 774 (8th Cir. 1993). Therefore, it
cannot be said that Congress did not intend a computer to be
considered “equipment” for the purpose of section 72(t)(2)(E).
Petitioners’ argument loses steam in their assertion that a
computer was “necessary” for Kathleen’s attendance at the
university. According to the Code, the computer must be
“required”. Sec. 529(e)(3). Notwithstanding the absence of
documentation from Miami University stating that it requires
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