§9023

ted Therapeutics’ position is the 111th Congress’s enactment, in 2010, of a new credit that relied on the same language as that used in section 45C(c)(2). Specifically, as part of the Patient Protection and Affordable Care Act, Pub. L. No. 111-148, § 9023(a), 124 Stat. 119, 877 (2010), the 111th Congress enacted a new “qualifying therapeutic discovery project credit” under section 48D. And it included in the new credit, in a paragraph entitled “Denial of a double benefit,” the following coordina

States v. Menasche, 348 U.S. 528, 538-539 (1955). Such an approach is a "cardinal principle ofstatutory construction". Williams v. Taylor, 529 U.S. 362, 404 (2000). Accordingly, we apply the plain meaning ofthe words set forth in section 48D and ACA sec. 9023, United States v. Am. Trucking Ass'ns, Inc., 310 U.S. 534, 543 (1940), and we do so mindful ofthe statutes as a whole. The relevant paragraphs ofsection 48D(b) provide: (1) In general.--Forpurposes ofsubsection (a), the qualified investment

Section 9023 ofthe Patient Protection and Affordable Care Act (ACA), Pub. L. No. 111-148, 124 Stat. at 877 (2010), providedFederal funding for a "qualifyingtherapeutic discovery project" (QTDP). This provision allowed taxpayersto claim a tax credit, codified in section 48D ofthe Code, or alternativelyto apply for a cash grant awarded by the Departm