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That is especially so here, where neither party’s grammar
argument is obviously more correct than the other’s. We do not
focus solely on such distinctions to decide the intent of
Congress in this case.
Normally, we begin our inquiry by looking to the plain
language of the statute to interpret its meaning. See Consumer
Prod. Safety Commn. v. GTE Sylvania, Inc., 447 U.S. 102, 108
(1980). When interpreting the words used in a statute, we give
them their ordinary meaning. See Jones v. Liberty Glass Co., 332
U.S. 524, 531 (1947). Considering the phrase “If any property
subject to a lease is acquired” we reach the conclusion that
either party’s interpretation is possible, depending on the
intent of Congress. The question we must answer is whether the
legislation was directed only to situations where a lease is to
continue beyond the time of acquisition of the property subject
to that lease or whether it applies to an acquisition of property
by a lessee where the lease merges into the lessee’s new
property ownership interest.
The legislative history provides no direct assistance or
decisive indicator to answer our particular inquiry. The
conference report contains the following general statement:
Interests under leases of tangible property.--The
term “section 197 intangible” does not include any
interest as a lessor or lessee under an existing lease
of tangible property (whether real or personal). The
cost of acquiring an interest as a lessor under a lease
of tangible property where the interest as lessor is
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