By: Derek Hawkins//September 7, 2021//
By: Derek Hawkins//September 7, 2021//
7th Circuit Court of Appeals
Case Name: U.S. Venture, Inc., v. United States of America
Case No.: 20-1861
Officials: SYKES, Chief Judge, and BRENNAN and SCUDDER, Circuit Judges.
Focus: Statutory Interpretation – Alternative Fuel Mixture Tax Credit
Statutory interpretation is familiar territory for federal courts, and this appeal requires us to resolve a dispute over the scope of a statutory credit—taken against excise fuel taxes—that Congress made available to producers of “alternative fuel mixtures.” U.S. Venture, a Wisconsin-based producer of motor fuels, argues that the tax credit applies to gasoline with a butane additive. The United States disagrees, contending that there is nothing alternative about gasoline containing a butane additive and that Congress made this plain through a combination of statutory provisions defining the scope of the alternative fuel mixture tax credit provided in 26 U.S.C. § 6426(e). The district court concluded that the government had the stronger position under the operative statutory and regulatory provisions. We agree.
Reading statutory text through a wholistic lens—giving effect to the language Congress enacted into law and interpreting that language in the context of the full statutory scheme—is the cornerstone of proper statutory construction and where U.S. Venture falls short. We affirm the district court’s entry of judgment for the government.
Affirmed