- 45 - 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 costPage: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Next
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