Is a cursory examination of a tax statute sufficient to invalidate a claim?

a cursory examination of [tax statutes may] disappear when they are read, as they must be, with every other material part of the statute, and in the light of their legislative history." Id. (citation omitted); see also Irwin v. Gavit, 268 U.S. 161, 168 (1925) ("It is said that the tax laws should be construed favorably for the taxpayers. But that is not a reason for creating a doubt or for exaggerating one when it is no greater than we can bring ourselves to feel in this case.").

Therefore, while tax statutes "are not to be extended by implication beyond the clear import of the language used," United States v. Merriam, 263 U.S. 179, 187-88 (1923), we do not mechanically resolve doubts in favor of the taxpayer but instead resort to the ordinary tools of statutory interpretation. Ultimately, "the literal meaning of the words employed is most important."⁴ Id.; see also United States v. Fei Ye, 436 F.3d 1117, 1120 (9th Cir. 2006) ("If the plain language of a statute renders its meaning reasonably clear, [we] will not investigate further unless

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