Lois E. Ordlock - Page 9

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          years.  Petitioner asserts that section 6015 requires this Court            
          to reallocate payments between petitioner and Mr. Ordlock based             
          on the economic sources, despite the continued existence of the             
          marital community.  This position has far-reaching implications             
          as it would cause us to read section 6015 as a statutory                    
          exception to the well-established law that State law defines                
          ownership interests in property for purposes of Federal tax                 
          collections under section 6321.  See United States v. Craft, 535            
          U.S. 274, 292 (2002); Aquilino v. United States, 363 U.S. 509,              
          513 (1960); United States v. Bess, 357 U.S. 51, 55 (1958); Morgan           
          v. Commissioner, 309 U.S. 78, 82 (1940).                                    
               The question here is whether Congress has given us a “clear            
          and unequivocal” intent to supplant community property law                  
          regarding payments of the type made on the Ordlocks’ joint tax              
          liability.  Powell v. Commissioner, 101 T.C. 489, 494 (1993).               
               B.   Statutory Interpretation and Construction                         
               Our analysis begins with the language of the statute.                  
          Consumer Prod. Safety Comm. v. GTE Sylvania, Inc., 447 U.S. 102,            
          108 (1980).  Statutes are to be read to give effect to their                
          plain and ordinary meaning unless that would produce absurd or              
          futile results.  United States v. Am. Trucking Associations,                
          Inc., 310 U.S. 534, 543 (1940); see Tamarisk Country Club v.                
          Commissioner, 84 T.C. 756, 761 (1985).  Moreover, where the                 
          language of a statute is clear on its face, we require                      
          unequivocal evidence of legislative purpose before construing the           




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