Medical Transportation Management Corporation - Page 10

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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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