- 12 - 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 isPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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