This statutory interpretation case raises the
primary question as to the plain (best) meaning of 26
U.S.C. § 7701(a)(48)(A)(i) and, in the context of the
federal excise tax scheme under 26 U.S.C. § 4051(a) ,
raises these four interrelated issues regarding the test
for applying that statutory exception :

1) What role does the ability of a vehicle to
transport a load over the highway play in the
statutory inquiry under 26 U.S.C. § 7701(a)(48)(A)(i) ?

2) Does the two-prong test under 26 U.S.C. §
7701(a)(48)(A)(i) require comparison of the vehicle in
question to a traditional highway vehicle to identify
the special design features and impairments or
limitations ?

3) Whether the phrase "specially designed for the
primary function of transporting a particular type of
load other than over the public highway…" as used in
26 U.S.C. § 7701(a)(48)(A)(i) require s consideration of
the design elements of the entire vehicle or just
particular components of the vehicle ?

4) Does the phrase "substantially limited or
impaired" as used in 26 U.S.C. § 7701( a)(48)(A)(i)
require consideration of all forms of impairment or
limitation ?

What is the proper statutory interpretation of 26 U.S.C. § 7701(a)(48)(A)(i) regarding the classification and taxation of specialized vehicles?