Interpreting Tax Legislation: The Role of Purpose

I want in a short space to provide a broad road map of my views regarding how one should approach the task of interpreting the Code and how purpose informs this task. The article starts with a brief exploration of the uncertainties surrounding the essential terms of the debate. Within the context of these uncertainties, it then explores several roles that purpose plays in different statutory situations. It concludes with some thoughts about the institutional issues at stake in the debate and a caution about reliance in statutory interpretation on what Professor Robert Summers calls a statute's "ultimate purpose."