Anschutz Company and Subsidiaries - Page 45

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          LTD. v. Commissioner, 84 T.C. 255, 277 (1985).  When there is no            
          indication that Congress intended the term to have a specific               
          meaning, courts may look to sources such as dictionaries for a              
          definition.  Keene v. Commissioner, supra at 14-15.                         
               Respondent argues that the dictionary meaning of                       
          “reasonable” should not be used because section 1.263A-1(f)(4),             
          Income Tax Regs., offers specific guidance as to its meaning.               
          However, as discussed above, the legislative history does not               
          suggest that Congress intended the reasonableness standard of               
          section 1.263A-1(f)(4), Income Tax Regs., to apply to section               
          1.263A-1(e)(3)(i) or 1.451-3(d)(6)(ii), Income Tax Regs.                    
          Therefore, we find that the term “reasonable” is not defined for            
          purposes of sections 1.263A-1(e)(3)(i) and 1.451-3(d)(6)(ii),               
          Income Tax Regs., and we may look to the dictionary definition of           
          the term to give it its ordinary meaning.                                   
               “Reasonable” is defined as “being in agreement with right              
          thinking or right judgment: not conflicting with reason * * *               
          possessing good sound judgment”.  Webster’s Third New                       
          International Dictionary 1892 (1993).  In other words, something            
          is reasonable if there is a  logic to it and a sound basis and              
          justification for it.  Because it is undefined in sections                  
          1.263A-1(e)(3)(i) and 1.451-3(d)(6)(ii), Income Tax Regs., we               
          give “reasonable” this meaning in interpreting the phrase                   
          “reasonable allocation”.  Accordingly, Qwest’s incremental cost             






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