Medical Transportation Management Corporation - Page 21

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               In conjunction with their ADA argument, petitioners argue              
          that one of the underlying purposes of section 6421 is to provide           
          relief for local mass transportation systems, and therefore we              
          must construe the statute to include paratransit providers as               
          beneficiaries in order to be consistent with and further this               
          purpose.  See Greyhound Corp. v. United States, 495 F.2d 863, 868           
          (9th Cir. 1974) (“Special relief is also provided, in the case of           
          gasoline, diesel fuel, and special motor-fuel taxes, for fuel               
          used in the operation of local or mass transportation systems.”             
          (quoting H. Rept. 2022, 84th Cong., 2d Sess. (1956), 1956-2 C.B.            
          1285, 1289)).  The legislative history of the statute as amended            
          in 1978, the statute which we are construing in this case, states           
          as the statute’s purpose “to encourage greater use of bus                   
          transportation.”  S. Rept. 95-529, supra at 54, 1978-3 C.B. (Vol.           
          2) at 246 (emphasis added).  Petitioner cites authority on                  
          statutory interpretation that notes that there is a presumption             
          against an implied repeal of legislative purpose.  However, we do           
          not consider our holding to conflict with the purpose of the                
          statute as originally enacted.  Nor do we find that the 1978                
          amendment intended to repeal the stated purpose of the 1956 act.            
          Rather, the 1978 amendment simply designated the scope of the               
          local mass transportation systems that Congress wanted to qualify           
          under section 6421.  We cannot accommodate petitioners’ request             
          to ignore words in the statute and gloss over stated                        






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