Id. at 1182. In Fort Howard Corp. v. Commissioner, 103 T.C. 345, 351 (1994), superseded by legislation and supplemented 107 T.C. 187 (1996), the Court analyzed section 162(k) which, at the time, prohibited deductions for amounts paid by a corporation “in connection with the redemption of its stock”. The issue before the Court was whether the costs incurred in obtaining debt financing to complete a leveraged buyout that was treated as a redemption were “in connection with” the corporation's redemption of its stock and therefore nondeductible under section 162(k).

Thus, as the amount of the loan increases, the amount of interchange increases, just as the amount of interest increases as the amount of the loan increases. As we said in Fort Howard Corp. & Subs. v. Commissioner, 103 T.C. 345, 374, 1994 WL 456807 (1994), modified on another issue 107 T.C. 187, 1996 WL 601859 (1996): “Crucial in establishing whether a particular payment constitutes interest is whether the payment bears some relationship to the amount borrowed”. See also Sharp v. Commissioner, 75 T.C. 21, 32, 1980 WL 4622 (1980), affd. 689 F.2d 87 (6th Cir.1982); Lay v. Commissioner, 69 T.C. 421, 438, 1977 WL 3678 (1977).

However, sec. 162(k) expressly distinguishes between “amounts properly allocated to indebtedness and amortized over the term of such indebtedness” and other stock reacquisition costs, exempting the former from the prohibition on deductions. Sec. 162(k)(2)(A)(ii); see Fort Howard Corp. v. Commissioner, 107 T.C. 187, 1996 WL 601859 (1996), supplementing 103 T.C. 345, 1994 WL 456807 (1994). We assume the amounts at issue would be exempted from sec. 162(k)(1)'s restrictions; in any event, neither party has raised this issue.

But when section 6103(h)(4)(A) was enacted in 1978, see Revenue Act of 1978, Pub. L. No. 95-600, § 503, 92 Stat. 2763, 2880, the term "connection" was defined broadly (and in relevant part) to mean any link, association, or relationship, see, e.g., Connection, The American Heritage Dictionary of the English Language, New College Edition (1976) ("2. Anything that joins, relates, or connects; a bond; a link. 3. An association, alliance, or relation . . . .");see also Fort Howard Corp. & Subs. v. Commissioner, 103 T.C. 345, 351-52 (1994) (citing Webster's Third New International Dictionary 480 (1986)), supplemented by 107 T.C. 187 (1996).

Two years after our Opinion in Fort Howard, Congress enacted retroactive relief for the borrowing expenses involved in both Fort Howard and Kroy. See Fort Howard Corp. & Subs. v. Commissioner, 107 T.C. 187, 1996 WL 601859 (1996). Ultimately, our holding in this case does not depend on our interpretation of the phrase “ in connection with” because we conclude that Congress expressly intended section 162(k) to prohibit deduction of the funds used to effect a redemption.

Commissioner v. Idaho Power Co., 418 U.S. at 17 (quoting Brooks v. Commissioner, 50 T.C. 927, 935 (1968), rev'd, 424 F.2d 116 (5th Cir. 1970)). Our conclusion here is also consistent with our decision in Fort Howard Corp. & Subs. v. Commissioner, 103 T.C. 345, 351 (1994), supplemented by 107 T.C. 187 (1996). There, we considered section 162(k)(1), which provided that "no deduction otherwise allowable shall be allowed under this chapter for any amount paid or incurred by a corporation in connection with the redemption of its stock."

In Smith, 159 T.C. at 55-56 (quoting Fort Howard Corp. & Subs. v. Commissioner, 103 T.C. 351 (1994), supplemented by 107 T.C. 187 (1996)), we read the term "other" in its "ordinary, everyday sense" and concluded that the reference in Delegation Order 4-12 (Rev. 3) to "other agreements" "refer[s] to agreements different from mutual agreements." Finally, petitioner views Delegation Order 8-3, IRM 1.2.47.4 (Aug. 18, 1997), as a more specific authority than Delegation Order 4-12 regarding the delegation of authority to sign closing agreements.

Those principles require us to interpret undefined terms in the delegation order "in their ordinary, everyday sense." See Fort Howard & Subs. v. Commissioner, 103 T.C. 345, 351-52 (1994) (citing Commissioner v. Soliman, 506 U.S. 168, 174 (1993)), supplemented by 107 T.C. 187 (1996); see also Food Mktg. Inst. v. Argus Leader Media, 139 S.Ct. 2356, 2362 (2019). As relevant here, the term "other" means "[d]ifferent from that or those implied or specified."

Two years after our Opinion in Fort Howard, Congress enacted retroactive relief for the borrowing expenses involved in both Fort Howard and Kroy. See Fort Howard Corp. Subs. v. Commissioner, 107 T.C. 187 (1996). Ultimately, our holding in this case does not depend on our interpretation of the phrase "in connection with" because we conclude that Congress expressly intended section 162(k) to prohibit deduction of the funds used to effect a redemption.

The phrase "in connection with" has been ascribed a broad meaning both with respect to section 162(k) and with respect to other statutory sections. See, e.g., Snow v. Commissioner, 416 U.S. 500, 502-503 (1974); Huntsman v. Commissioner, 905 F.2d 1182, 1184 (8th Cir. 1990), revg. and remanding 91 T.C. 917 (1988); Ft. Howard Corp. v. Commissioner, 103 T.C. 345 (1994), supplemented by 107 T.C. 187 (1996). An expense, however, does not fall within the broad meaning afforded it under section 162(k) simply because the expense is paid at a time that is proximate to a redemption.