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Whether payments for services are considered benefits appears an
open question, though at least The American Heritage Dictionary
of the English Language supports that view. Dictionary
definitions of the term “benefit” do not allow us to eliminate
from the meaning of the term “payments received in connection
with the performance of services” (as respondent implicitly
argues). We next look to see whether Congress understood the
term “benefit” to include a payment of the sort at issue here.
D. Context
While the titles of statutes and statutory headings cannot
limit the plain meaning of statutory text, they are of some use
for interpretative purposes when they shed some light on
ambiguous words or phrases. Bhd. of R.R. Trainmen v. B&O R.R.
Co., 331 U.S. 519, 528-529 (1947).
Title 38 (2000) is entitled “VETERANS’ BENEFITS”. Section
1718 falls within the following subdivisions of title 38: part
II, “GENERAL BENEFITS”; chapter 17, “HOSPITAL, NURSING HOME,
DOMICILIARY, AND MEDICAL CARE”; and subchapter II, “HOSPITAL,
NURSING HOME, OR DOMICILIARY CARE AND MEDICAL TREATMENT”. As
stated, section 1718 is entitled “Therapeutic and rehabilitative
activities”. As pertinent to the statutory hierarchy, section
1718 therapeutic work programs clearly fall within the ambit of
medical benefits (medical care and medical treatment) provided to
veterans. Distributions from the VA Special Therapeutic and
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