author: Justice O’Connor

text:
    DAVIS et ux. v. UNITED STATES
    No. 89-98.
    Argued March 26, 1990
    Decided May 21, 1990

      O’Connor, J., delivered the opinion for a unanimous Court.

      Rex E. Lee argued the cause for petitioners. With him on the brief were Carter G. Phillips and Bart M. Davis.

      Assistant Attorney General Peterson argued the cause for the United States. With her on the brief were Solicitor General Starr, Deputy Solicitor General Wallace, Alan I. Horowitz, David I. Pincus, and Francis M. Allegra.

        Wilford W. Kirton, Jr., Raeburn G. Kennard, and Robert P. hunt filed a brief for the Church of Jesus Christ of Latter-day Saints as amicus curiae urging reversal.

   Justice O’Connor

delivered the opinion of the Court.

We are called upon in this case to determine whether the funds petitioners transferred to their two sons while they served as full-time, unpaid missionaries for the Church of Jesus Christ of Latter-day Saints (Church) are deductible as charitable contributions “to or for the use of” the Church, pursuant to 26 U. S. C. § 170 (1982 ed.).

I

Petitioners, Harold and Enid Davis, and their sons, Benjamin and Cecil, are members of the Church. According to the stipulated facts, the Church operates a worldwide missionary program involving 25,000 persons each year. Most of these missionaries are young men between ages 19 and 22. If the Church determines that a candidate is qualified to become a missionary, the president of the Church sends a letter calling the candidate to missionary service in a specified geographical location. A follow-up letter from the missionary department lists the items of clothing the missionary will need, provides specific information relating to the mission, and sets forth the estimated amount of money needed to support the missionary service. This amount varies according to the location of the mission and reflects an estimate of the amount the missionary will actually need.

The missionary’s parents generally provide the necessary funds to support their son or daughter during the period of missionary service. If they are unable to do so, the Church will locate another donor from the local congregation or use money donated to the Church’s general missionary funds. The Church believes that having individual donors send the necessary funds directly to the missionary benefits the Church in several important ways. Specifically, it “fosters the Church doctrine of sacrifice and consecration in the lives of its people” as well as reducing the administrative and bookkeeping requirements which would otherwise be imposed upon the Church. App. to Pet. for Cert. 32a.

After accepting the call, the missionary candidate receives priesthood ordinances to serve as an official missionary and minister of the Church. During the missionary service, the mission president (leader of the mission) controls many aspects of the missionaries’ lives, including the manner of dress and grooming. Missionaries are required to conform to a daily schedule which calls for at least 10 hours per day of actual missionary work in addition to study time, mealtime, and planning time. Mission rules forbid dating, movies, plays, certain sports, and other activities; missionaries are not allowed to take vacations or travel for personal purposes.

Missionaries receive some supervision over their use of funds. The Missionary Handbook instructs missionaries that “[t]he money you receive for your support is sacred and should be spent wisely and only for missionary work. Keep expenses at a minimum. . . . Keep a financial record of all expenditures.” App. 13. The mission presidents give similar instructions to the missionaries under their supervision. Although missionaries are not required to obtain advance approval of each expenditure they make from their personal checking account, they do submit weekly reports to their group leader listing the amount of time spent in Church service, the type of missionary work accomplished, and a report of the total expenses for the week and month to date. If a missionary begins to accumulate surplus funds, he is expected to take action to reduce the amount of donations sent to him. The mission president may alter his estimates of the amounts required each month to take into account changing circumstances.

Benjamin and Cecil Davis both applied to become missionaries. In 1979, the Church notified Benjamin by letter that he had been called to missionary service at the New York Mission. A second letter informed him of the estimated amount of money which would be needed to support his service. In 1980, Cecil Davis was notified that he had been called to missionary service at the New Zealand-Cook Island Mission. Cecil also received a second letter informing him about the mission and the amount of money he would need. Petitioners notified their bishop that they would provide the funds requested by the Church to meet their sons’ mission expenses. According to petitioners, both sons made a commitment with them to use the money only in accordance with the Church’s instructions.

Petitioners transferred to Benjamin’s personal checking account, on which he was the sole authorized signatory, $8,480.89 in 1980 and $4,135 in 1981. During 1981, petitioners transferred $1,518 to Cecil’s personal checking account, on which he was the sole authorized signatory. Benjamin and Cecil used this money primarily to pay for rent, food, transportation, and personal needs while on their missions. Benjamin also spent approximately $20 per month to purchase religious tracts and other materials used during his missionary work. Neither Benjamin nor Cecil was required to seek or sought specific approval of each expenditure made from his personal checking account. However, each week Benjamin and Cecil submitted a report of the total expenses for the week and month to date. At the end of their service, Cecil had no money remaining in his account; Benjamin had $150 which he used to purchase a camera. (Petitioners do not claim a deduction for this amount.)

In their joint tax returns filed in 1980 and 1981, petitioners claimed their sons as dependents, but did not claim a charitable contribution deduction under 26 U. S. C. § 170 for the funds sent their sons during their missionary service. On April 16, 1984, petitioners filed an amended income tax return for the years 1980 and 1981, claiming additional charitable contributions of the $3,480.89 and $4,882 paid to their sons during the missionary service. In J anuary 1985, the Internal Revenue Service disallowed the refunds. Petitioners filed a refund suit in the United States District Court for the District of Idaho. In September 1986, petitioners filed a second set of amended returns, limiting their charitable deductions to the amounts indicated by the Church and correcting the number of dependents claimed for each year.

In District Court, petitioners and the United States both moved for summary judgment. 664 F. Supp. 468 (Idaho 1987). Petitioners argued that the payments they made to support their sons’ missionary services were charitable contributions “for the use of” the Church. Alternatively, they claimed the payments were deductible under Treas. Reg. 1.170A-l(g), 26 CFR §1.170A-l(g) (1989), which allows the deduction of “unreimbursed expenditures made incident to the rendition of services to an organization contributions to which are deductible.” The District Court ruled in favor of the United States. It rejected petitioners’ claimed deduction for unreimbursed expenditures because petitioners were not themselves performing donated services, and it held that petitioners’ payments to their sons were not “for the use of” the Church because the Church lacked sufficient possession and control of the funds. 664 F. Supp., at 471-472.

The Court of Appeals for the Ninth Circuit affirmed. 861 F. 2d 558 (1988). The Court of Appeals rejected petitioners’ claim that the transferred funds were deductible contributions because they conferred a benefit on the Church. Id., at 561. Instead, the Court of Appeals held that contributions are deductible only when the recipient charity exercises control over the donated funds. Id., at 562. The Court of Appeals reasoned that the beneficiary of a charitable contribution must be indefinite, see Russell v. Allen, 107 U. S. 163, 167 (1883), and that this requirement cannot be met when the taxpayer makes a contribution directly to the intended beneficiary. In this case, the Court of Appeals concluded that the Church lacked actual control over the disposition of the funds and thus they were not deductible. 861F. 2d, at 562. The Court of Appeals agreed with the District Court that § 1.170A-l(g) did not apply to petitioners, as the regulation permits a deduction for unreimbursed expenses only by the taxpayer who performed the charitable service. Id., at 564.

Because the Court of Appeals’ decision conflicted with White v. United States, 725 F. 2d 1269, 1270-1272 (CA10 1984), and Brinley v. Commissioner, 782 F. 2d 1326, 1336 (CA5 1986), we granted certiorari, 493 U. S. 953 (1990), and now affirm.

II

Under § 170 of the Internal Revenue Code of 1954, 68A Stat. 58, as amended, 26 U. S. C. § 170 (1982 ed.), a taxpayer may claim a deduction for a charitable contribution only if the contribution is made “to or for the use of” a qualified organization. This section provides, in pertinent part:

“(a) Allowance of deduction.
“(1) General rule. —There shall be allowed as a deduction any charitable contribution (as defined in subsection (c)) payment of which is made within the taxable year. A charitable contribution shall be allowable as a deduction only if verified under regulations prescribed by the Secretary.
“(c) Charitable contribution defined. — For purposes of this section, the term ‘charitable contribution’ means a contribution or gift to or for the use of—
“(2) A corporation, trust, or community chest, fund, or foundation—
“(B) organized and operated exclusively for religious, charitable, scientific, literary, or educational purposes . . . .” (Emphasis added.)

Petitioners contend that the funds they transferred to their sons’ accounts are deductible as contributions “for the use of” the Church. Alternatively, petitioners claim these funds are unreimbursed expenditures under Treasury Regulation §1.170A-l(g) and therefore are deductible as contributions “to” the Church. We first consider whether the payments at issue here are “for the use of” the Church within the meaning of § 170.

On its face, the phrase “for the use of” could support any number of different meanings. See, e. g., Webster’s New International Dictionary (2d ed. 1950) (“use” defined in general usage as “to convert to one’s service”; “to employ”; or, in law, “use imports a trust” relationship). Petitioners contend that the phrase “for the use of” must be given its broadest meaning as describing “the entire array of fiduciary relationships in which one person conveys money or property to someone else to hold or employ in some manner for the benefit of a third person.” Brief for Petitioners 17. Under this reading, no legally enforceable relationship need exist between the recipient of the donated funds and the qualified donee; in effect, any intermediary may handle the funds in any way that would arguably benefit a charitable organization, regardless of how indirect or tangential the benefit might be. Petitioners also advance a second, somewhat narrower interpretation, specifically that a contribution is “for the use of” a qualified organization within the meaning of § 170 so long as the donee has “a reasonable ability to ensure that the contribution primarily serves the organization’s charitable purposes.” Id., at 26. In this case, petitioners argue that their payments at least meet this second interpretation. They point to the Church’s role in requesting the funds, setting the amount to be donated, and requiring weekly expense sheets from the missionaries. The Service, on the other hand, has historically defined “for the use of” as conveying “a similar meaning as ‘in trust for.’” See, e. g., I. T. 1867, II — 2 Cum. Bull. 155 (1923).

Although the language of § 170 would support the interpretation of either the Service or petitioners, the events leading to the enactment of the 1921 amendment adding the phrase “for the use of” to § 170 indicate that Congress had a specific meaning of “for the use of” in mind. The original version of § 170, promulgated in the War Revenue Act of 1917, ch. 63, § 1201(2), 40 Stat. 330, did not allow deductions for gifts “for the use of” a qualified donee. Rather, it allowed individuals to deduct only “[contributions or gifts . . . to corporations or associations organized and operated exclusively for religious, charitable, scientific, or educational purposes. ...” In interpreting this provision in the Act (and in the subsequent Revenue Act of 1918, ch. 18, §214(a)(ll), 40 Stat. 1068), the Bureau of Internal Revenue stated that “[contributions to a trust company (a corporation) in trust to invest and disburse them for a charitable purpose are not allowable deductions under [§ 170].” O. D. 669, 3 Cum. Bull. 187 (1920). In hearings before the Senate Committee on Finance on the proposed Revenue Act of 1921, representatives of charitable foundations requested an amendment making gifts to trust companies and similar donees deductible even though a trustee, rather than a charitable organization, held legal title to the funds. Hearings on Proposed Revenue Act of 1921 before the Senate Committee on Finance, 67th Cong., 1st Sess., 521 (1921). Testimony before the Committee indicated that numerous communities had established charitable trusts, charitable foundations, or community chests so that individuals could donate money to a trustee who held, invested, and reinvested the principal, and then turned the principal over to a committee that distributed the funds for charitable purposes. Id., at 522-526; see also H. R. Rep. No. 350, 67th Cong., 1st Sess., 12 (1921) (House Comm, on Ways and Means) (amendments “would allow the deduction, under proper restriction, of contributions or gifts to a community chest fund or foundation”); S. Rep. No. 275, 67th Cong., 1st Sess., 18 (1921). Responding to these concerns, Congress overruled the Bureau’s interpretation of § 170 (then § 214(a)(ll)) by adding the phrase “for the use of. . . any corporation, or community chest, fund, or foundation. . .’’to the charitable deduction provision of the Revenue Act of 1921, ch. 136, § 214(a)(ll), 42 Stat. 241. In light of these events, it can be inferred that Congress’ use of the phrase “for the use of” related to its purpose in amending § 170 of allowing taxpayers to deduct contributions made to trusts, foundations, and similar donees. An interpretation of “for the use of” as conveying a similar meaning as “in trust for” would be consistent with this goal.

It would have been quite natural for Congress to use the phrase “for the use of” to indicate its intent of allowing deductions for donations in trust, as this phrase would have suggested a trust relationship to the members of the 67th Congress. From the dawn of English common law through the present, the word “use” has been employed to refer to various forms of trust arrangements. See 1 G. Bogert, Trusts and Trustees § 2, p. 9 (1935); Black’s Law Dictionary 1382 (5th ed. 1979) (“Uses and trusts are not so much different things as different aspects of the same subject. A use regards principally the beneficial interest; a trust regards principally the nominal ownership”). In the early part of this century, the word “use” was technically employed to refer to a passive trust, but less formally used as a synonym for the word “trust.” See Bogert, swpra, at 9 (“The words ‘use’ and ‘trust’ are employed as synonyms frequently by writers and judges”); 1 R. Baldes, Perry on Trusts and Trustees §298 (7th ed. 1929) (“A use, a trust, and a confidence is one and the same thing . . .”); 1 Restatement of Trusts §§67-72 (Effect of Statute of Uses) (1935). The phrases “to the use of” or “for the use of” were frequently used in describing trust arrangements. See, e. g., United States v. Bowling, 256 U. S. 484, 486 (1921); Blanset v. Cardin, 256 U. S. 319, 321 (1921); Rand v. United States, 249 U. S. 503, 508 (1919). Given that this meaning of the word “use” precisely corresponded with Congress’ purpose for amending the statute, it appears likely that in choosing the phrase “for the use of” Congress was referring to donations made in trust or in a similar legal arrangement.

This understanding is confirmed by the Bureau’s initial interpretation of the phrase. It is significant that almost immediately following the amendment of §170, the Commissioner interpreted the phrase “for the use of” as “intended to convey a similar meaning as ‘in trust for.’” I. T. 1867, II — 2 Cum. Bull. 155 (1923). Rejecting a taxpayer’s claim that a gift to a volunteer fire company was deductible as a contribution for the use of the municipality, the Bureau noted that “[i]t does not appear that the municipality in any way has any control over the property of the incorporated volunteer fire company or that it has any voice in the manner in which such property should be used. Upon dissolution of the company, the property would not escheat to the State. A right of appropriation or enjoyment of the property of the fire company does not rest in the municipality.” Ibid. The Service adhered to its interpretation that “for the use of” conveys “a similar meaning as ‘in trust for’ ” in subsequent rulings permitting taxpayers to deduct the value of gifts irrevocably transferred to a trust for the benefit of qualified organizations. See, e. g., Rev. Rul. 55-275, 1955-1 Cum. Bull. 295; Rev. Rul. 194, 1953-2 Cum. Bull. 128; I. T. 3707, 1945 Cum. Bull. 114. Numerous judicial decisions have relied on this interpretation. See, e. g., Rockefeller v. Commissioner, 676 F. 2d 35, 40 (CA2 1982); Orr v. United States, 343 F. 2d 553, 557-558 (CA5 1965); Thomason v. Commissioner, 2 T. C. 441, 444 (1943); Danz v. Commissioner, 18 T. C. 454, 464 (1952), aff’d on other grounds, 231 F. 2d 673 (CA9 1955), cert. denied, 352 U. S. 828 (1956). Congress’ reenactment of the statute in 1954, using the same language, indicates its apparent satisfaction with the prevailing interpretation of the statute. See Cammarano v. United States, 358 U. S. 498, 510 (1959); McCaughn v. Hershey Chocolate Co., 283 U. S. 488, 492-493 (1931).

The Commissioner’s interpretation of “for the use of” thus appears to be entirely faithful to Congress’ understanding and intent in using that phrase. Moreover, the Commissioner’s interpretation is consistent with the purposes of § 170 as a whole. In enacting § 170, “Congress sought to provide tax benefits to charitable organizations, to encourage the development of private institutions that serve a useful public purpose or supplement or take the place of public institutions of the same kind.” Bob Jones University v. United States, 461 U. S. 574, 588 (1983). The Commissioner’s interpretation of “for the use of” assures that contributions will in fact foster such development because it requires contributions to be made in trust or in some similar legal arrangement. A defining characteristic of a trust arrangement is that the beneficiary has the legal power to enforce the trustee’s duty to comply with the terms of the trust. See, e. g., 3 W. Fratcher, Scott on Trusts § 200 (4th ed. 1988); 1 Restatement of Trusts § 200 (1935). A qualified beneficiary of a bona fide trust for charitable purposes would have both the incentive and legal authority to ensure that donated funds are properly used. If the trust contributes funds to a range of charitable organizations so that no single beneficiary could enforce its terms, the trustee’s duty can be enforced by the Attorney General under the laws of most States. See 4A W. Fratcher, Scott on Trusts §391 (4th ed. 1989); G. Bogert, Trusts and Trustees §411 (2d ed. 1977). Although the Service’s interpretation does not require that the qualified organization take actual possession of the contribution, it nevertheless reflects that the beneficiary must have significant legal rights with respect to the disposition of donated funds.

Petitioners argue that any interpretation of “for the use of” that requires a qualified donee to have the same degree of control over contributed funds as a beneficiary would have over a trust res would make “for the use of” redundant, meaning no more than “to.” We disagree. When Congress amended § 170, it was fully aware of the Bureau’s ruling that the original statutory deduction for contributions “to” a qualified organization could not be claimed for contributions made in trust for the organization. See O. D. 669, 3 Cum. Bull. 187 (1920). Accordingly, Congress amended the statute specifically to overcome this interpretation. Moreover, a contribution made in trust for a charity does not give the charity immediate possession and control, as does a donation directly to a charity. Unlike a contribution that must go “to” a qualified organization, a contribution “for the use of” a donee may go to a trustee with the discretion to select among a number of qualified donees to whom the funds may be disbursed. See, e. g., Bowman v. Commissioner, 16 B. T. A. 1157, 1163-1164 (1929). Furthermore, a taxpayer may generally claim an immediate deduction for a gift to a trustee, even though receipt of the gift by the charity is delayed. Recognizing this characteristic of gifts in trust, Congress further amended § 170 in 1964 in order to encourage donations “to” a charity, because donations “in trust for” a charity “often do not find their way into operating philanthropic endeavors for extended periods of time.” S. Rep. No. 830, 88th Cong., 2d Sess., 59-60 (1964).

Although the Service’s interpretive rulings do not have the force and effect of regulations, see Bartels v. Birmingham, 332 U. S. 126, 132 (1947), we give an agency’s interpretations and practices considerable weight where they involve the contemporaneous construction of a statute and where they have been in long use. See, e. g., Norwegian Nitrogen Products Co. v. United States, 288 U. S. 294, 315 (1933). Under the circumstances presented here, we think there is good reason to accept the Service’s interpretation of “for the use of.” The denial of deductions for donations in trust that prompted Congress to amend § 170, the accepted meaning of “use” as synonymous with the term “trust,” and the Service’s contemporaneous and longstanding construction of § 170 constitute strong evidence in favor of this interpretation.

Although the language of the statute may also bear petitioners’ interpretation, they have failed to establish that their interpretation is compelled by the statutory language. To the contrary, there is no evidence that Congress intended the phrase “for the use of” to be interpreted as referring to fiduciary relationships in general or as referring to a type of relationship that gives a qualified organization a reasonable ability to supervise the use of contributed funds. Rather, as noted above, there are strong indications that Congress intended a more specific meaning. Moreover, petitioners’ interpretations would tend to undermine the purposes of § 170 by allowing taxpayers to claim deductions for funds transferred to children or other relatives for their own personal use. Because a recipient of donated funds need not have any legal relationship with a qualified organization, the Service would face virtually insurmountable administrative difficulties in verifying that any particular expenditure benefited a qualified donee. Cf. § 170(a)(1). Although there is no suggestion whatsoever in this case that the transferred funds were used for an improper purpose, it is clear that petitioners’ interpretation would create an opportunity for tax evasion that others might be eager to exploit. See, e. g., Scialabba, Kurtzman, & Steinhart, Mail-Order Ministries Under the Section 170 Charitable Contribution Deduction: The First Amendment Restrictions, the Minister’s Burden of Proof, and the Effect of TRA ’86, 11 Campbell L. Rev. 1 (1988); Note, “I Know It When I See It”: Mail-Order Ministry Tax Fraud and the Problem of a Constitutionally Acceptable Definition of Religion, 25 Am. Crim. L. Rev. 113 (1987). We need not determine whether petitioners’ interpretation of “for the use of” would have been a permissible one had the Service decided to adopt it, though we note that the Service may retain some flexibility to adopt other interpretations in the future. It is sufficient to decide this case that the Service’s longstanding interpretation is both consistent with the statutory language and fully implements Congress’ apparent purpose in adopting it. Accordingly, we conclude that a gift or contribution is “for the use of” a qualified organization when it is held in a legally enforceable trust for the qualified organization or in a similar legal arrangement.

Viewing the record here in the light most favorable to petitioners, as we must after a grant of summary judgment for the United States, we discern no evidence that petitioners transferred funds to their sons “in trust for” the Church. It is undisputed that petitioners transferred the money to their sons’ personal bank accounts on which the sons were the sole authorized signatories. Nothing in the record indicates that petitioners took any steps normally associated with creating a trust or similar legal arrangement. Although the sons may have promised to use the money “in accordance with Church guidelines,” see App. to Pet. for Cert. 36a, they did not have any legal obligation to do so; there is no evidence that the guidelines have any legally binding effect. Nor does the record support the assertion, see Tr. of Oral Arg. 19-20, that the Church might have a legal entitlement to the money or a civil cause of action against missionaries who used their parents’ money for purposes not approved by the Church. We conclude that, because petitioners did not donate the funds in trust for the Church, or in a similarly enforceable legal arrangement for the benefit of the Church, the funds were not donated “for the use of” the Church for purposes of § 170.

Ill

Petitioners contend, in the alternative, that their transfer of funds into their sons’ account was a contribution “to” the Church under Treas. Reg. § 1.170A-l(g), 26 CFR §1.170A-l(g) (1989), which provides:

“Contributions of services. No deduction is allowable under section 170 for a contribution of services. However, unreimbursed expenditures made incident to the rendition of services to an organization contributions to which are deductible may constitute a deductible contribution. For example, the cost of a uniform without general utility which is required to be worn in performing donated services is deductible. Similarly, out-of-pocket transportation expenses necessarily incurred in performing donated services are deductible. Reasonable expenditures for meals and lodging necessarily incurred while away from home in the course of performing donated services also are deductible. For the purposes of this paragraph, the phrase ‘while away from home! has the same meaning as that phrase is used for purposes of section 162 and the regulations thereunder.”

Petitioners assert that this regulation allows them to claim deductions for their sons’ unreimbursed expenditures incident to their sons’ contribution of services. We disagree. The plain language of § 1.170A-l(g) indicates that taxpayers may claim deductions only for expenditures made in connection with their own contributions of service to charities. Unless there is a specific statutory provision to the contrary, a taxpayer ordinarily reports his own income and takes his own deductions. See, e. g., Commissioner v. Culbertson, 337 U. S. 733, 739-740 (1949) (“[T]he first principle of income taxation [is] that income must be taxed to him who earns it”); New Colonial Ice Co. v. Helvering, 292 U. S. 435, 440-441 (1934) (“[T]axpayer who sustain[s] the loss is the one to whom the deduction shall be allowed”). Section 1.170A-l(g) is thus most naturally read as referring to the individual taxpayer, who may deduct only those “unreimbursed expenditures” incurred in connection with the taxpayer’s own “rendition of services to [a qualified] organization.” This interpretation of the regulation is consistent with the Revenue Ruling that was the precursor to § 1.170A-l(g). See Rev. Rul. 55-4, 1955-1 Cum. Bull. 291 (“A taxpayer who gives his services gratuitously to an association, contributions to which are deductible under [§ 170] and who incurs unreimbursed traveling expenses . . . may deduct the amount of such unreimbursed expenses in computing his net income . . .”). It would strain the language of the regulation to read it, as petitioners suggest, as allowing a deduction for expenses made incident to a third party’s rendition of services rather than to the taxpayer’s own contribution of services. Similarly, the taxpayer is clearly intended to be the subject of the other provisions in the regulation. For example, it is most natural to read the regulation as referring to a taxpayer who incurs expenditures for meals and lodging while away from his home, not while a third party is away from his home.

Petitioners’ interpretation not only strains the language of the statute, but would also allow manipulation of §1.170A-1(g) for tax evasion purposes. See Note, Does Charity Begin at Home? The Tax Status of a Payment to an Individual as a Charitable Deduction, 83 Mich, L. Rev. 1428, 1434-1435 (1985); Brinley v. Commissioner, 782 F. 2d, at 1338 (Hill, J. dissenting). For example, parents might be tempted to transfer funds to their children in amounts greater than needed to reimburse reasonable expenses incurred in donating services to a charity. Parents and children might attempt to claim a deduction for the same expenditure. Controlling such abuses would place a heavy administrative burden on the Service, which would not only have to monitor the taxpayer’s records, but also correlate them with the records of the third party. To the extent petitioners’ interpretation lessens the likelihood that claimed charitable contributions actually served a charitable purpose, it is inconsistent with § 170.

Petitioners cite judicial decisions that allowed taxpayers to claim deductions for the expenses of third parties who assisted the taxpayers in rendering services to qualified organizations. See, e. g., Rockefeller v. Commissioner, 676 F. 2d 35 (CA2 1982); McCollum v. Commissioner, 37 TCM 1817 (1978); Smith v. Commissioner, 60 T. C. 988 (1973). These cases are inapposite, as petitioners do not claim that they were independently rendering services to the Church, assisted by their sons.

We conclude that § 1.170A-l(g) does not allow taxpayers to claim a deduction for expenses not incurred in connection with the taxpayers’ own rendition of services to a qualified organization. Therefore, petitioners are not entitled to a deduction under § 1.170A-l(g).

Petitioners also assert that because their sons are agents of. the Church authorized to receive payments to support their own missionary efforts, payments made to their sons are payments to the Church. Because this argument was neither raised before nor decided by the Court of Appeals, we decline to address it here. See, e. g., Delta Air Lines, Inc. v. August, 450 U. S. 346, 362 (1981); United States v. Mendenhall, 446 U. S. 544, 551-552, n. 5 (1980).

Accordingly, we hold that petitioners’ transfer of funds into their sons’ accounts was not a contribution “to or for the use of” the Church for purposes of § 170. The judgment of the Court of Appeals is

Affirmed.

      The Commissioner has adopted the holding in Rockefeller v. Commissioner, 676 F. 2d 35, 42 (CA2 1982), that unreimbursed expenses are contributions “to” the Church rather than “for the use of” the Church. See Rev. Rui. 84-61, 1984-1 Cum. Bull. 40.


source: Caselaw Access Project

license: Public Domain

text:
    CALIFORNIA v. FEDERAL ENERGY REGULATORY COMMISSION et al.
    No. 89-333.
    Argued March 20, 1990
    Decided May 21, 1990

      O’Connor, J., delivered the opinion for a unanimous Court.

      Roderick E. Walston, Deputy Attorney General of California, argued the cause for petitioner. With him on the briefs were John K. Van de Kamp, Attorney General, R. H. Connett, Assistant Attorney General, and Clifford T. Lee, Deputy Attorney General.

      Stephen L. Nightingale argued the cause for respondents. With him on the brief for respondent Federal Energy Regulatory Commission were Solicitor General Starr, Deputy Solicitor General Merrill, Jerome M. Feit, Joseph S. Davies, and Raymond E. Hagenlock. Louis Touton and Erwin N. Griswold filed a brief for respondent Rock Creek Limited Partnership.

      Briefs of amici curiae urging reversal were filed for the State of Idaho et al. by Jim Jones, Attorney General, and Clive J. Strong, Deputy Attorney General, and by the Attorneys General for their respective States as follows: Don Siegelman of Alabama, Douglas B. Baily of Alaska, Robert K. Corbin of Arizona, Steve Clark of Arkansas, Duane Woodard of Colorado, Clarine Nardi Riddle of Connecticut, Charles M. Oberly III of Delaware, Robert A. Buttenvorth of Florida, Michael J. Boioers of Georgia,
        Warren Price III of Hawaii, Neil F. Hartigan of Illinois, Linley E. Pearson of Indiana, Tom Miller of Iowa, Robert T. Stephan of Kansas, Frederic J. Cowan of Kentucky, William J. Guste, Jr., of Louisiana, James E. Tierney of Maine, J. Joseph Curran, Jr., of Maryland, James M. Shannon of Massachusetts, Frank J. Kelley of Michigan, Hubert H. Humphrey III of Minnesota, Mike Moore of Mississippi, William L. Webster of Missouri, Marc Racicot of Montana, Robert M. Spire of Nebraska, Brian McKay of Nevada, John P. Arnold of New Hampshire, Peter N. Perretti, Jr., of New Jersey, Hal Stratton of New Mexico, Robert Abrams of New York, Lacy H. Thornburg of North Carolina, Nicholas Spaeth of North Dakota, Anthony J. Celebrezze, Jr., of Ohio, Robert H. Henry of Oklahoma, Have Frohnmayer of Oregon, Ernest D. Preate, Jr., of Pennsylvania, James E. O’Neil of Rhode Island, T. Travis Medlock of South Carolina, Roger A. Tellinghuisen of South Dakota, Charles W. Burson of Tennessee, Jim Mattox of Texas, Paul Van Dam of Utah, Jeffrey L. Amestoy of Vermont, Mary Sue Teiry of Virginia, Kenneth O. Eikenberry of Washington, Roger Tompkins of West Virginia, Donald J. Hanaivay of Wisconsin, and Joseph B. Meyer of Wyoming; for American Rivers et al. by Steven W. Weston; and for the Council of State Governments et al. by Benna Ruth Solomon and Richard J. Lazarus.

      Briefs of amici curiae urging affirmance were filed for the City of Klamath Falls, Oregon, by Edward Weinberg and Richmond F. Allan; for the Edison Electric Institute et al. by Jerome C. Muys, Peter Kelsey, Robert L. McCarty, Wallace F. Tillman, and William J. Madden; for the Modesto Irrigation District et al. by Joel S. Moskowitz and Gregory J. Kerivin; for Pacific Gas and Electric Company et al. by Jack F. Fallin, Jr., Howard V. Golub, Thomas H. Nelson, and Jody L. Williams; and for Pacific Northwest Utilities by Jay T. Waldron.

        Antonio Cosby-Rossmann filed a brief for the County of Inyo et al. as amici curiae.

   Justice O’Connor

delivered the opinion of the Court.

This case concerns overlapping federal and state regulation of a hydroelectric project located near a California stream. California seeks to ensure that the project’s operators maintain water flowing in the stream sufficient, in the State’s judgment, to protect the stream’s fish. The Federal Government claims the exclusive authority to set the minimum stream flows that the federally licensed powerplant must maintain. Each side argues that its position is consistent with the Federal Power Act, ch. 285, 41 Stat. 1063, as amended, 16 U. S. C. §791a et seq. (1982 ed.), and, in particular, with §27 of that Act. We granted certiorari to resolve these competing claims.

I

The Rock Creek hydroelectric project lies near the confluence of the South Fork American River and one of the river’s tributaries, Rock Creek. Rock Creek runs through federally managed land located within California. The project draws water from Rock Creek to drive its generators and then releases the water near the confluence of the stream and river, slightly less than one mile from where it is drawn. The state and federal requirements at issue govern the “minimum flow rate” of water that must remain in the bypassed section of the stream and that thus remains unavailable to drive the generators.

In 1983, pursuant to the Federal Power Act (FPA or Act), the Federal Energy Regulatory Commission (FERC) issued a license authorizing the operation of the Rock Creek project. Keating, 23 FERC ¶ 62,137. Section 4(e) of the FPA empowers FERC to issue licenses for projects “necessary or convenient... for the development, transmission, and utilization of power across, along, from, or in any of the streams . . . over which Congress has jurisdiction.” 16 U. S. C. § 797(e) (1982 ed.). Section 10(a) of the Act also authorizes FERC to issue licenses subject to the conditions that FERC deems best suited for power development and other public uses of the waters. 16 U. S. C. §803(a) (1982 ed.). Congress’ subsequent amendments to those provisions expressly direct that FERC consider a project’s effect on fish and wildlife as well as “power and development purposes.” Electric Consumers Protection Act of 1986, Pub. L. 99-495, 100 Stat. 1243, 16 U. S. C. §§ 797(e), 803(a)(1). FERC issued the 1983 license and set minimum flow rates after considering the project’s economic feasibility and environmental consequences. In part to protect trout in the stream, the license required that the project maintain interim minimum flow rates of 11 cubic feet per second (cfs) during May through September and 15 cfs during the remainder of the year. 23 FERC ¶ 62,137, at 63,204. The license also required the licensee to submit studies recommending a permanent minimum flow rate, after consulting with federal and state fish and wildlife protection agencies. Ibid. In 1985, the licensee submitted a report recommending that FERC adopt the interim flow rates as permanent rates. The California Department of Fish and Game (CDFG) recommended that FERC require significantly higher minimum flow rates.

The licensee had also applied for state water permits, and in 1984 the State Water Resources Control Board (WRCB) issued a permit that conformed to FERC’s interim minimum flow requirements but reserved the right to set different permanent minimum flow rates. App. 65-67. When the WRCB in 1987 considered a draft order requiring permanent minimum flow rates of 60 cfs from March through June and 30 cfs during the remainder of the year, the licensee petitioned FERC for a declaration that FERC possessed exclusive jurisdiction to determine the project’s minimum flow requirements. Rock Creek Limited Partnership, 38 FERC ¶ 61,240, p. 61,772 (1987). The licensee, by then respondent Rock Creek Limited Partnership, also claimed that the higher minimum flow rates sought by the WRCB would render the project economically infeasible. Ibid.

In March 1987, FERC issued an order directing the licensee to comply with the minimum flow requirements of the federal permit. In that order, FERC concluded that the task of setting minimum flows rested within its exclusive jurisdiction. Id., at 61,774. The Commission reasoned that setting minimum flow requirements was integral to its planning and licensing process under FPA § 10(a); giving effect to competing state requirements “would interfere with the Commission’s balancing of competing considerations in licensing” and would vest in States a veto power over federal projects inconsistent with the FPA, as interpreted in First Iowa Hydro-Electric Cooperative v. FPC, 328 U. S. 152 (1946). 38 FERC, at 61,773. FERC also directed an Administrative Law Judge to hold a hearing to determine the appropriate permanent minimum flow rates for the project. Id., at 61,774. After considering proposals and arguments of the licensee, the CDFG, and FERC staff, the Administrative Law Judge set the minimum flow rate for the project at 20 cfs during the entire year. Rock Creek Limited Partnership, 41 FERC ¶ 63,019 (1987). Four days after FERC’s declaratory order, the WRCB issued an order directing the licensee to comply with the higher minimum flow requirements contained in its draft order. App. 73. The WRCB also intervened to seek a rehearing of FERC’s order. FERC denied the rehearing request, concluded that the State sought to impose conflicting license requirements, and reaffirmed its conclusion that the FPA, as interpreted in First Iowa, provided FERC with exclusive jurisdiction to determine minimum flow rates. Rock Creek Limited Partnership, 41 FERC ¶ 61,198 (1987).

The Court of Appeals for the Ninth Circuit affirmed FERC’s order denying rehearing. California ex rel. State Water Resources Board v. FERC, 877 F. 2d 743 (1989). That court, too, concluded that First Iowa governed the case; that FPA §27 as construed in First Iowa did not preserve California’s right to regulate minimum flow rates; and that the FPA pre-empted WRCB’s minimum flow rate requirements. Ibid. We granted certiorari, 493 U. S. 991 (1989), and we now affirm.

II

In the Federal Power Act of 1935, 49 Stat. 863, Congress clearly intended a broad federal role in the development and licensing of hydroelectric power. That broad delegation of power to the predecessor of FERC, however, hardly determines the extent to which Congress intended to have the Federal Government exercise exclusive powers, or intended to pre-empt concurrent state regulation of matters affecting federally licensed hydroelectric projects. The parties’ dispute regarding the latter issue turns principally on the meaning of § 27 of the FPA, which provides the clearest indication of how Congress intended to allocate the regulatory authority-of the States and the Federal Government. That section provides:

“Nothing contained in this chapter shall be construed as affecting or intending to affect or in any way to interfere with the laws of the respective States relating to the control, appropriation, use, or distribution of water used in irrigation or for municipal or other uses, or any vested right acquired therein.” 16 U. S. C. §821 (1982 ed.).

Were this a case of first impression, petitioner’s argument based on the statute’s language could be said to present a close question. As petitioner argues, California’s minimum stream flow requirement might plausibly be thought to “re-latte] to the control, appropriation, use, or distribution of water used . . . for. . . other uses,” namely the generation of power or the protection of fish. This interpretation would accord with the “presumption against finding pre-emption of state law in areas traditionally regulated by the States” and “ ‘with the assumption that the historic police powers of the States were not to be superseded by the Federal Act unless that was the clear and manifest purpose of Congress.’” California v. ARC America Corp., 490 U. S. 93, 101 (1989), quoting Rice v. Santa Fe Elevator Corp., 331 U. S. 218, 230 (1947); see California v. United States, 438 U. S. 645, 653-663 (1978) (tracing States’ traditional powers over exploitation of water). Just as courts may not find state measures pre-empted in the absence of clear evidence that Congress so intended, so must they give full effect to evidence that Congress considered, and sought to preserve, the States’ coordinate regulatory role in our federal scheme.

But the meaning of §27 and the pre-emptive effect of the FPA are not matters of first impression. Forty-four years ago, this Court in First Iowa construed the section and provided the understanding of the FPA that has since guided the allocation of state and federal regulatory authority over hydroelectric projects. The Court interpreted § 27 as follows:

“The effect of § 27, in protecting state laws from supersedure, is limited to laws as to the control, appropriation, use or distribution of water in irrigation or for municipal or other uses of the same nature. It therefore has primary, if not exclusive, reference to such proprietary rights. The phrase ‘any vested right acquired therein’ further emphasizes the application of the section to property rights. There is nothing in the paragraph to suggest a broader scope unless it be the words ‘other uses.’ Those words, however, are confined to rights of the same nature as those relating to the use of water in irrigation or for municipal purposes.” First Iowa, 328 U. S., at 175-176 (emphasis added).

The Court interpreted § 27’s reservation of limited powers to the States as part of the congressional scheme to divide state from federal jurisdiction over hydroelectric projects and, “in those fields where rights are not thus ‘saved’ to the States ... to let the supersedure of the state laws by federal legislation take its natural course.” Id., at 176.

We decline at this late date to revisit and disturb the understanding of §27 set forth in First Iowa. As petitioner prudently concedes, Tr. of Oral Arg. 7, First Iowa’s interpretation of § 27 does not encompass the California regulation at issue: California’s minimum stream flow requirements neither reflect nor establish “proprietary rights” or “rights of the same nature as those relating to the use of water in irrigation or for municipal purposes.” First Iowa, supra, at 176; see Fullerton v. State Water Resources Control Board, 90 Cal. App. 3d 590, 153 Cal. Rptr. 518 (1979); accord, California Trout, Inc. v. State Water Resources Control Board, 90 Cal. App. 3d 816, 153 Cal. Rptr. 672 (1979). Instead, petitioner requests that we repudiate First Iowa’s interpretation of § 27 and the FPA. This argument misconceives the deference this Court must accord to longstanding and well-entrenched decisions, especially those interpreting statutes that underlie complex regulatory regimes. Adherence to precedent is, in the usual case, a cardinal and guiding principle of adjudication, and “[considerations of stare decisis have special force in the area of statutory interpretation, for here, unlike in the context of constitutional interpretation, the legislative power is implicated, and Congress remains free to alter what we have done.” Patterson v. McLean Credit Union, 491 U. S. 164, 172-173 (1989). There has been no sufficient intervening change in the law, or indication that First Iowa has proved unworkable or has fostered confusion and inconsistency in the law, that warrants our departure from established precedent. Cf. id., at 173. This Court has endorsed and applied First Iowa’s limited reading of §27, see FPC v. Oregon, 349 U. S. 435 (1955); cf. FPC v. Niagara Mohawk Power Corp., 347 U. S. 239 (1954), and has employed the decision with approval in a range of decisions, both addressing the FPA and in other contexts. See, e. g., New England Power Co. v. New Hampshire, 455 U. S. 331, 338, n. 6 (1982); Escondido Mut. Water Co. v. La Jolla Band of Mission Indians, 466 U. S. 765, 773 (1984); City of Tacoma v. Taxpayers of Tacoma, 357 U. S. 320, 334 (1958); Pacific Gas & Electric Co. v. State Energy Resources Conservation and Development Comm’n, 461 U. S. 190, 223, n. 34 (1983). By directing FERC to consider the recommendations of state wildlife and other regulatory agencies while providing FERC with final authority to establish license conditions (including those with terms inconsistent with the States’ recommendations), Congress has amended the FPA to elaborate and reaffirm First Iowa’s understanding that the FPA establishes a broad and paramount federal regulatory role. See 16 U. S. C. §§ 803(a)(l)-(3) (FERC to issue license on conditions that protect fish and wildlife, after considering recommendations of state agencies), as amended by the Electric Consumers Protection Act of 1986, 16 U. S. C. §§803(j) (1) — (2) (FERC license conditions protecting fish and wildlife to be based on recommendations of federal and state wildlife agencies, with FERC to issue findings if it adopts conditions contrary to recommendations); cf. Square D Co. v. Niagara Frontier Tariff Bureau, Inc., 476 U. S. 409, 424 (1986) (“We are especially reluctant to reject this presumption [of adherence to precedent] in an area that has seen careful, intense, and sustained congressional attention”).

Petitioner asks this Court fundamentally to restructure a highly complex and long-enduring regulatory regime, implicating considerable reliance interests of licensees and other participants in the regulatory process. That departure would be inconsistent with the measured and considered change that marks appropriate adjudication of such statutory issues. See Square D Co., supra, at 424 (for statutory determinations, “‘it is more important that the applicable rule of law be settled than that it be settled right. . . . This is commonly true, even where the error is a matter of serious concern, provided correction can be had by legislation,’” quoting Burnet v. Coronado Oil & Gas Co., 285 U. S. 393, 406 (1932) (Brandeis, J., dissenting)).

Petitioner also argues that we should disregard First Iowa’s discussion of § 27 because it was merely dictum. It is true that our immediate concern in First Iowa was the interpretation of § 9(b) of the FPA, which governs submission to the federal licensing agency of evidence of compliance with state law. The Court determined that § 9(b) did not require licensees to obtain a state permit or to demonstrate compliance with the state law prerequisites to obtaining such a permit. First Iowa, 328 U. S., at 163-164, 167, 177. Instead, the Court construed the section merely as authorizing the federal agency to require evidence of actions consistent with the federal permit. Id., at 167-169, 177-179. First Iowa’s limited reading of § 27 was, however, necessary for, and integral to, that conclusion. Like this case, First Iowa involved a state permit requirement that related to the control of water for particular uses but that did not relate to or establish proprietary rights. Iowa had required as one condition of securing a state permit that diverted water be “returned ... at the nearest practicable place without being materially diminished in quantity or polluted or rendered deleterious to fish life,” Iowa Code §7771 (1939), a provision the Court found to conflict with the federal requirements and to “strik[e] at the heart of the present project.” First Iowa, 328 U. S., at 166-167, 170-171. The Court reasoned that, absent an express congressional command, § 9(b) could not be read to require compliance with, and thus to preserve, state laws that conflicted with and were otherwise pre-empted by the federal requirements. See id., at 166-167 (“If a state permit is not required, there is no justification for requiring the petitioner, as a condition of securing its federal permit, to present evidence of the petitioner’s compliance with the requirements of the State Code for a state permit”); id., at 177. Only the Court’s narrow reading of § 27 allowed it to sustain this interpretation of § 9(b). Had § 27 been given the broader meaning that Iowa sought, it would have “saved” the state requirements at issue, made the state permit one that could be issued, and supported the interpretation of § 9(b) as requiring evidence of compliance with those state requirements, rather than compliance only with those requirements consistent with the federal license.

The Court’s related, but more general, rationale for its reading of § 9(b) in First Iowa also necessarily rested on its narrow construction of § 27. The Court framed the issue as whether the Act allowed the States to regulate through permit requirements such as Iowa’s “the very requirements of the project that Congress has placed in the discretion of the Federal Power Commission.” Id., at 165 (footnote citing FPA § 10(a) omitted). The Court rejected the possibility of concurrent jurisdiction and interpreted the FPA as mandating divided powers and “a dual system involving the close integration of these powers rather than a dual system of futile duplication of two authorities over the same subject matter.” Id., at 171; see id., at 174 (no “divided authority over any one subject”); id., at 181 (comprehensive federal role “leave[s] no room or need for conflicting state controls”). Section 9 reflected the operation of this exclusive federal authority. See id., at 167-169; id., at 168 (“Where the Federal Government supersedes the state government there is no suggestion that the two agencies both shall have final authority”). In accord with this view, the Court interpreted § 9(b) as requiring compliance only with state measures relevant to federal requirements rather than, as would exist under a system of concurrent jurisdiction, compliance with the state requirements necessary to secure the state permit. Id., at 167-169. Instead, only §27 preserved and defined the States’exclusive regulatory sphere. Id., at 175-178. That is, the Court rejected an interpretation of §9(b) that would have “saved” or accommodated the state permit system and its underlying requirements. To reach its interpretation of § 9(b), however, the Court had to interpret § 27 consistently with the limited state regulatory sphere and in a manner that did not, by “saving” the Iowa requirements, establish “divided authority over any one subject.” Id., at 174. Constricting § 27 to encompass only laws relating to proprietary rights, and thus leaving the permit requirements at issue to the federal sphere, accomplished that goal. The Court’s discussion immediately after its extended discussion of § 27 illustrates the relation between the sections. Before distinguishing §27’s role in saving state law from §9(b)’s role in the sphere of exclusive federal regulation, the Court concluded:

“[Section 27] is therefore thoroughly consistent with the integration rather than the duplication of federal and state jurisdictions under the Federal Power Act. It strengthens the argument that, in those fields where rights are not thus “saved” to the States, Congress is willing to let the supersedure of the state laws by federal legislation take its natural course.” Id., at 176.

The Court’s interpretation of § 9(b), of course, rested on that supersedure and required that the remaining field “saved” to the States by § 27 be limited correspondingly.

Petitioner also argues that our decision in California v. United States, 438 U. S. 645 (1978), construing § 8 of the Reclamation Act of 1902, requires that we abandon First Iowa’s interpretation of § 27 and the FPA. Petitioner reasons that § 8 is similar to, and served as a model for, FPA § 27, that this Court in California v. United States interpreted § 8 in a manner inconsistent with First Iowa’s reading of § 27, and that that reading of § 8, subsequent to First Iowa, in some manner overrules or repudiates First Iowa’s understanding of §27. California v. United States is cast in broad terms and embodies a conception of the States’ regulatory powers in some tension with that set forth in First Iowa, but that decision bears quite indirectly, at best, upon interpretation of the FPA. The Court in California v. United States interpreted the Reclamation Act of 1902; it did not advert to, or purport to interpret, the FPA, and held simply that § 8 requires the Secretary of the Interior to comply with state laws, not inconsistent with congressional directives, governing use of water employed in federal reclamation projects. California v. United States, supra. Also, as in First Iowa, the Court in California v. United States examined the purpose, structure, and legislative history of the entire statute before it and employed those sources to construe the statute’s saving clause. See 438 U. S., at 649-651, 653-670, 674-675. Those sources indicate, of course, that the FPA envisioned a considerably broader and more active federal oversight role in hydropower development than did the Reclamation Act. Compare FPA §§4, 9, 10, as codified, 16 U. S. C. §§797, 802, 803, and First Iowa, 328 U. S., at 164, 167-169, 171-174, 179-181, with Reclamation Act of 1902 §§ 1, 2, 32 Stat. 388, as codified, 43 U. S. C. §§391, 411 (1982 ed.), and California v. United States, supra, at 649-651, 663-670.

Even if the two saving clauses were properly viewed in isolation from the remainder of their respective Acts and resulting regulatory schemes, significant differences exist between them. Section 8 of the Reclamation Act, after referring to state water laws relating to water used in irrigation and preserved by the Act, contains an explicit direction that “the Secretary of the Interior, in carrying out the provisions of this Act, shall proceed in conformity with such [state] laws.” 43 U. S. C. §383 (1982 ed.). This language has no counterpart in § 27 of the FPA and was crucial to the Court’s interpretation of §8. See California v. United States, supra, at 650, 664-665, 674-675. Although California v. United States and First Iowa accord different effect to laws relating to water uses, this difference stems in part from the different roles assumed by the federal actor in each case, as reflected in § 8’s explicit directive to the Secretary. The Secretary in executing a particular reclamation project is in a position analogous to a licensee under the FPA and need not comply with state laws conflicting with congressional directives respecting particular reclamation projects, see 438 U. S., at 672-674; similarly, a federal licensee under the FPA need not comply with state requirements that conflict with the federal license provisions established pursuant to the FPA’s directives. An additional textual difference is that § 8 refers only to “water used in irrigation” and contains no counterpart to §27’s reference to “other uses,” the provision essential to petitioner’s argument. Laws controlling water used in irrigation relate to proprietary rights, as the First Iowa Court indicated, 328 U. S., at 176, and n. 20, and § 8 does not indicate the appropriate treatment of laws relating to other water uses that do not implicate proprietary rights.

Given these differences between the statutes and saving provisions, it should come as no surprise that California v. United States did not refer either to §27 or to First Iowa. Since the Court decided California v. United States, we have continued to cite First Iowa with approval. See, e. g., Escondido Mut. Water Co., 466 U. S., at 773; Pacific Gas & Electric Co., 461 U. S., at 223, n. 34; New England Power Co., 455 U. S., at 338, n. 6. We do not believe that California v. United States requires that we disavow First Iowa in this case.

Finally, petitioner argues that §27’s legislative history requires us to abandon First Iowa’s interpretation of that section. Whatever the usefulness of legislative history for statutory interpretation in the usual case, that source provides petitioner with no aid. If a quite natural reading of the statutory language fails to displace an intervening decision providing a contrary interpretation, legislative history supporting that reading and by definition before the Court that has already construed the statute provides little additional reason to overturn the decision. Cf. Patterson, 491 U. S., at 172-174 (reviewing sources most likely to prompt overruling of decision). Indeed, First Iowa expressly considered the legislative history of the FPA and of § 27 in particular and found that source to support its interpretation of both. First Iowa, supra, at 171-174, 176, n. 20, 179. Given the tangential relation of the legislative history to the issue at hand and the interests supporting adherence to First Iowa, we decline to parse again the legislative history to determine whether the Court in First Iowa erred in its understanding of the development, as well as the meaning, of the statute.

Adhering to First Iowa’s interpretation of §27, we conclude that the California requirements for minimum in-stream flows cannot be given effect and allowed to supplement the federal flow requirements. A state measure is “pre-empted to the extent it actually conflicts with federal law, that is, when it is impossible to comply with both state and federal law, or where the state law stands as an obstacle to the accomplishment of the full purposes and objectives of Congress.” Silkwood v. Kerr-McGee Corp., 464 U. S. 238, 248 (1984) (citations omitted). As Congress directed in FPA § 10(a), FERC set the conditions of the license, including the minimum stream flow, after considering which requirements would best protect wildlife and ensure that the project would be economically feasible, and thus further power development. See Rock Creek Limited Partnership, 41 FERC ¶ 63,019 (1987); Keating, 23 FERC ¶ 62,137 (1983); see also Rock Creek Limited Partnership, 41 FERC ¶61,198 (1987). Allowing California to impose significantly higher minimum stream flow requirements would disturb and conflict with the balance embodied in that considered federal agency determination. FERC has indicated that the California requirements interfere with its comprehensive planning authority, and we agree that allowing California to impose the challenged requirements would be contrary to congressional intent regarding the Commission’s licensing authority and would “constitute a veto of the project that was approved and licensed by FERC.” 877 F. 2d, at 749; cf. First Iowa, supra, at 164-165.

For the foregoing reasons, the decision of the Court of Appeals for the Ninth Circuit is

Affirmed.

       Section 9(b), 16 U. S. C. §802(a)(2) (formerly 16 U. S. C. §802(b) (1982 ed.)), provides:
      “(a) Each applicant for a license under this chapter shall submit to the commission—
      “(2) Satisfactory evidence that the applicant has complied with the requirements of the laws of the State or States within which the proposed project is to be located with respect to bed and banks and to the appropriation, diversion, and use of water for power purposes and with respect to the right to engage in the business of developing, transmitting and distributing power, and in any other business necessary to effect the purposes of a license under this chapter.”

       Section 8 of the Reclamation Act of 1902, 32 Stat. 390, now 43 U. S. C. §§ 372, 383 (1982 ed.), provided in part:
      “[N]othing in this Act shall be construed as affecting or intended to affect or in any way interfere with the laws of any State or Territory relating to the control, appropriation, use, or distribution of water used in irrigation, or any vested right acquired thereunder, and the Secretary of the Interior, in carrying out the provisions of this Act, shall proceed in conformity with such laws, and nothing herein shall in any way affect any right of any State or of the Federal Government or of any landowner, appropriator, or user of water in, to, or from any interstate stream or the waters thereof . . .