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1978-3 C.B. (Vol. 2) at 247 (emphasis added). The legislative
history does not define “bus”, which leaves us with the ordinary
meaning of the word “bus” that we have already stated petitioners
do not qualify under.
We conclude that the sedans do not qualify as “buses”. Even
though the legislative history petitioners cite plausibly
includes vans, we do not need to evaluate whether any vans
petitioners used qualify as buses because our finding that sedans
are not buses precludes an application of the credit.
Petitioners failed to give an accounting of how many gallons of
gas to attribute to each type of vehicle for purposes of the
gasoline credit. See sec. 6421(b)(1). Therefore, even if we
were to hold that vans qualify as buses, petitioners fail to
qualify for the gasoline credit because we have no way of
discerning how many gallons of gasoline were used by either type
of vehicle.4
III. “Regular Route” Requirement
Since petitioners did not use gasoline in an “automobile
bus,” they are not entitled to an income tax credit under section
34(a)(2). Nevertheless, for the sake of completeness, we shall
determine whether petitioners provided transportation that meets
4Neither party has raised the question of burden of proof,
but petitioners have the initial burden of coming forward with
evidence. Rule 142(a).
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