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(1993)(quoting Perrin v. United States, 444 U.S. 37, 42 (1979));
see also Crane v. Commissioner, 331 U.S. 1, 6 (1947) (“Words of
statutes--including revenue acts--should be interpreted where
possible in their ordinary, everyday senses”). Therefore, we
shall look to the ordinary meaning of the word “bus” to determine
whether petitioners’ sedans and vans qualify as buses.
In determining the ordinary meaning of a statutory term, we
first look to the ordinary usage or settled meanings of the words
used in the statute by Congress. Hamm v. James, 406 F.3d 1340,
1343 (11th Cir. 2005); Hefti v. Commissioner, 97 T.C. 180, 193
(1991), affd. 983 F.2d 868 (8th Cir. 1993). The word “bus” is
short for the word “omnibus” and is commonly defined as “a large
motor-driven vehicle designed to carry passengers usu. according
to a schedule along a fixed route”. Webster’s Third New
International Dictionary (1993); see also Webster’s Tenth New
Collegiate Dictionary (2002) for a similar definition. We
address whether the vehicles petitioners use meet the definition
of “fixed” or “regular” routes in detail infra pp. 16-20 in
examining whether petitioners meet the third requirement for
obtaining the credit. Notwithstanding the question of fixed
routes, we do not believe that the 4-passenger sedans petitioners
used qualify as large motor vehicles. Petitioners submitted
closeup photographs of the sedans in question, and it is fairly
obvious that the vehicles are not large, even for a sedan.
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