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the collection of which is being challenged. The dollar limit in
section 7463(f)(2) is a condition that must be met before a
section 6330 collection case can qualify to be conducted as a
small tax case in the same manner as a case described in
subsection (a). If Congress had intended that the $50,000
limitation in subsection (f)(2) be applied to the amount of tax
for each year, period, or taxable event, it surely knew how to do
so; and it presumably would have used the same terminology as in
section 7463(a).8
In interpreting a statute, our purpose is to give effect to
Congress’s intent. Fernandez v. Commissioner, 114 T.C. 324, 329
(2000); see also Gati v. Commissioner, 113 T.C. 132, 133 (1999).
We begin with the statutory language. Allen v. Commissioner, 118
T.C. 1, 7 (2002) (and cases cited therein). Usually, the plain
meaning of the statutory language is conclusive. United States
v. Ron Pair Enters., Inc., 489 U.S. 235, 242 (1989); Woodral v.
Commissioner, 112 T.C. 19, 23 (1999). “When a statute appears to
be clear on its face, there must be unequivocal evidence of
legislative purpose before interpreting the statute so as to
override the plain meaning of the words used therein.” Fernandez
v. Commissioner, supra at 330; see also Huntsberry v.
8 Sec. 7436, dealing with employment taxes, contains
language similar to that of sec. 7463(a); i.e., the tax may not
exceed $50,000 for each quarter in order for the case to qualify
for small tax case procedures. See supra note 7.
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