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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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