Several well established principles of statutory construction guide our interpretation of section 6 1 113. We initially rely on the language of the statute, giving words and phrases their plain and ordinary meaning. See Moody v. Corsentino, 843 P.2d 1355, 1370 (Colo. 1993); People v. Guenther, 740 P.2d 971, 975 (Colo. 1987). We must give [...]

[25] Reductions in excessive assessments, as opposed to assessments which become legally unenforceable in their entirety, are governed by the abatement statute, 26 U.S.C. § 6404(a): [26] (a) The Secretary is authorized to abate the unpaid portion of the assessment of any tax or any liability in respect thereof, which – [27] (1) is excessive [...]