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not of limitation. See, e.g., Fed. Land Bank v. Bismarck Lumber
Co., 314 U.S. 95, 100 (1941) (the term “including” used in a
section of the Federal Farm Loan Act of July 17, 1916, ch. 245,
39 Stat. 380, is not one of all-embracing definition but connotes
simply an illustrative application of a general principle);
Chemehuevi Indian Tribe v. Cal. State Bd. of Equalization, 757
F.2d 1047, 1054 (9th Cir. 1985) (definitional term “includes”
used in a section of the California Revenue and Taxation Code
governing cigarette tax is one of enlargement, not of
limitation), revd. on other grounds 474 U.S. 9 (1985); Heffner v.
Ketchen, 296 P. 768, 770 (Idaho 1931) (the word “including” used
in an Idaho tax lien statute is generally a term of enlargement,
may be used as a word of addition, and indicates something not
included, being sometimes used as equivalent to “also” or “and”).
Of particular interest is the fact that the word “includes”
as used in the Internal Revenue Code (or its predecessors) has
been interpreted by the courts broadly. See, e.g., Fid. Trust
Co. v. Commissioner, 141 F.2d 54, 57 (3d Cir. 1944) (in view of
section 1111(b), a trust was considered a transferee although
section 526(f) of the Internal Revenue Code of 1932, ch. 209, 47
Stat. 257, defining transferee, did not enumerate trusts as part
of the definition of “transferee”); Cannon v. Nicholas, 80 F.2d
934, 936 (10th Cir. 1935) (“the word ‘including’ * * * has
various shades of meaning, sometimes of restriction and sometimes
of enlargement” and as used in a predecessor of the Internal
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