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the proposition that it would be contrary to congressional intent
to subject the gains that it realized on the sale of the 11
homesites to unrelated business income tax. S. Rept. 91-552, at
72-73 (1969), 1969-3 C.B. 423, 470-471, states in pertinent part:
In addition, the committee's bill provides that
the tax on investment income is not to apply to the
gain on the sale of assets used by the organizations in
the performance of their exempt functions to the extent
the proceeds are reinvested in assets used for such
purposes within a period beginning 1 year before the
date of sale and ending three years after that date.
This provision is to be implemented by rules similar to
those provided where a taxpayer sells or exchanges his
residence (sec. 1034). The committee believes that it
is appropriate not to apply the tax on investment
income in this case because the organization is merely
reinvesting the funds formerly used for the benefit of
its members in other types of assets to be used for the
same purpose. They are not being withdrawn for gain by
the members of the organization. For example, where a
social club sells its clubhouse and uses the entire
proceeds to build or purchase a larger clubhouse, the
gain on the sale will not be taxed if the proceeds are
reinvested in the new clubhouse within three years.
Relying on this excerpt, petitioner argues that it would be
inappropriate to subject the gains in question to unrelated
business income tax where the gains were immediately reinvested
in new recreational facilities.
As previously noted, where a statutory provision is clear on
its face, we require unequivocal evidence of legislative purpose
before construing the statute so as to override the plain meaning
of the words used therein. Halpern v. Commissioner, 96 T.C. 895,
899 (1991). Although petitioner immediately reinvested its gains
in new recreational facilities used in the performance of its
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