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congressional intent to achieve an overly broad interpretation
that allows petitioners to qualify for the credit.
V. Conclusion
Petitioners do not qualify under the section 34 credit for
gasoline taxes because the transportation they provided did not
meet the requirements enumerated in section 6421. Petitioners’
sedans did not qualify as buses, and petitioners did not provide
any evidence for us to bifurcate the credit allowed toward their
vans that may have possibly qualified. Thus we decline to reach
that issue of whether the vans qualify in light of the failure of
proof. Nor were petitioners’ transportation services scheduled
and along regular routes. The routes petitioners traveled day-
to-day were subject to change based on a myriad of factors. None
of the constructions of the statutes petitioners offered were
persuasive.
To reflect the foregoing,
Decisions will be entered for
respondent.
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