Medical Transportation Management Corporation - Page 22

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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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