- 16 - Rehabilitation Activities Fund are nested within a series of provisions dealing with benefits. There is a canon of construction, noscitur a sociis (Latin: “it is known by its associates”), holding that the meaning of an unclear word or phrase should be determined by the words immediately surrounding it. Black’s Law Dictionary 1087 (8th ed. 2004); see also, e.g., Jarecki v. G.D. Searle & Co., 367 U.S. 303, 307 (1961). While Congress has failed to tell us whether distributions from the VA Special Therapeutic and Rehabilitation Activities Fund are to be considered benefits, the placement of section 1718 in the midst of so many benefit provisions supports the inference that such distributions are to be considered benefits. Contextually, the distributions are benefits. E. History of 38 U.S.C. Section 5301(a) The history of a statute may be helpful in resolving ambiguities therein. E.g., Anderson v. Commissioner, 123 T.C. 219, 233 (2004), affd. 137 Fed. Appx. 373 (1st Cir. 2005). Section 5301 (2000) of title 38 both limits the assignability of veterans’ benefits and exempts those benefits from taxation. While the provision has deep roots,5 its 5 The tax exemption for VA benefits originated as an amendment to the Bureau of War Risk Insurance Act, which, beginning in 1917, provided certain benefits for members of the Armed Forces. See Act of Oct. 6, 1917, ch. 105, sec. 311, 40 Stat. 408. The initial amendment, which provided an exemption from tax for certain death and disability benefits, was later (continued...)Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: November 10, 2007