PSB Holdings, Inc. - Page 14




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          or that such an application “‘would thwart the purpose of the               
          overall statutory scheme or lead to an absurd or futile result.’”           
          Booth v. Commissioner, 108 T.C. 524, 568, 569 (1997) (quoting               
          Garcia v. United States, 469 U.S. 70, 76 n.3 (1984), and                    
          Albertson’s, Inc. v. Commissioner, 42 F.3d 537, 545 (9th Cir.               
          1994), affg. 95 T.C. 415 (1990)); see United States v. Am.                  
          Trucking Associations, Inc., supra at 543; see also United States           
          v. Shriver, 989 F.2d 898, 901 (7th Cir. 1992); Allen v.                     
          Commissioner, 118 T.C. 1 (2002).                                            
               The applicable text refers to “the taxpayer’s average                  
          adjusted [bases] * * * of [tax-exempt] obligations” and the                 
          “average adjusted bases for all assets of the taxpayer”.  We read           
          that text to refer to the tax-exempt obligations and assets owned           
          by Peoples alone or, in other words, by the “taxpayer” for whom             
          the subject calculation is performed.  We do not read that text             
          to provide that a taxpayer such as Peoples must include in its              
          tax-exempt obligations any tax-exempt obligation purchased and              
          owned by another taxpayer, whether the taxpayers be related or              
          not.  Cf. First Chicago NBD Corp. v. Commissioner, 135 F.3d 457             
          (7th Cir. 1998) (holding that section 902 did not allow                     
          aggregation where the statute referred literally to “a”                     
          corporation rather than to a group of affiliated corporations),             
          affg. 96 T.C. 421 (1991).  We understand Congress to have enacted           
          the text as a means for raising revenue and bolstering equity in            







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