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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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