- 9 - 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 avoidPage: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007