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adjective form of “automobile” to describe bus, which is commonly
defined as “automotive”, meaning “containing within itself the
means of propulsion”. Id.
We agree with respondent’s interpretation. There is no
evidence that Congress intended the plain meaning of “automobile”
to alter or expand the plain meaning of the word “bus”. The
legislative history accompanying section 6421 clarifies that
Congress meant only buses should qualify for the credit: “the
bill provides for the refund or credit of the taxes paid on
gasoline and other motor fuels but only to the extent these fuels
are used in a bus engaged in furnishing (for compensation)
passenger land transportation available to the general public”.
S. Rept. 95-529, supra at 56, 1978-3 C.B. (Vol. 2) at 248
(emphasis added). Even if we were to accept petitioners’
interpretation of the word “automobile bus”, petitioners would
not meet their own definition because as discussed infra pp. 16-
19, the transportation petitioners provided was not on fixed or
regularly scheduled routes.2
B. The Legislative History to Section 6421 Does Not
Support Petitioners’ Interpretation
Petitioners argue that the following language from the
2Respondent cites extensive legislative history that shows
how the word “automobile” has been used as a modifier in various
statutes predating the Code. While that argument may have some
merit, we find that it is not dispositive and therefore does not
control our analysis.
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