Michael Patrick and Debye Lee Leahy - Page 9

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               Section 7463(f)(2) refers to the case of “an appeal under              
          section 6330(d)(1)(A) to the Tax Court of a determination in                
          which the unpaid tax does not exceed $50,000.”  (Emphasis added.)           
          The words “in which” could conceivably refer back to either “an             
          appeal” or “a determination”.  An “appeal” within the meaning of            
          section 7463(f)(2) occurs when the taxpayer petitions the Tax               
          Court.  However, if the words “in which” were meant to refer to             
          “an appeal”, then inclusion of the words “of a determination”               
          immediately preceding “in which the unpaid tax does not exceed              
          $50,000” would be rendered surplusage and could have been                   
          omitted.  Statutory language is interpreted by giving each word             
          its plain, obvious, and rational meaning.  Am. Tobacco Co. v.               
          Patterson, 456 U.S. 63, 68 (1982); United States v. Merriam, 263            
          U.S. 179, 187-188 (1923); Liddle v. Commissioner, 103 T.C. 285,             
          293 n.4 (1994), affd. 65 F.3d 329 (3d Cir. 1995).  Fundamental              
          principles of statutory construction generally preclude us from             
          reading a statute in such a way as to render statutory language             
          mere surplusage.  Zapara v. Commissioner, 126 T.C. 215, 231                 
          (2006); see also United States v. Campos-Serrano, 404 U.S. 293,             
          301 n.14 (1971).  Failure to give any meaning to the words “of a            
          determination” in interpreting section 7463(f)(2) would violate             
          these canons of statutory construction.  In addition, it is a               
          general rule of style and composition to position a modifying               
          word or clause close to the term it explains in order to avoid              

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