Hubert Enterprises, Inc. and Subsidiaries, et al. - Page 48

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          * * * are placed in service in any taxable year of the                      
          partnership or S corporation”.  Sec. 465(c)(2)(B)(i).                       
               Petitioners read the quoted text, with a focus especially on           
          the word “any”, to mean that all of LCL’s equipment leasing                 
          activities are viewed as a single activity, notwithstanding the             
          fact that all of the activities did not arise in the same taxable           
          year.  We read that text differently.  While petitioners focus              
          primarily on the single word “any” to support their                         
          interpretation, the word “any” may not be construed in isolation            
          but must be construed in the context of the statute as a whole.             
          See Small v. United States,     U.S.    , 125 S. Ct. 1752 (2005);           
          United States v. Alvarez-Sanchez, 511 U.S. 350, 357 (1994).                 
          Statutes should be interpreted as a whole to give effect to every           
          clause, sentence, and word therein, see Market Co. v. Hoffman,              
          101 U.S. 112, 115 (1879), and the duty of a court is to render              
          that type of interpretation whenever possible, cf. United States            
          v. Menasche, 348 U.S. 528, 538-539 (1955); Montclair v. Ramsdell,           
          107 U.S. 147, 152 (1883).  Such an approach is a “cardinal                  
          principle of statutory construction”.  Williams v. Taylor,                  
          529 U.S. 362, 404 (2000).                                                   
               In accordance with that approach, we apply the plain meaning           
          of the words set forth in section 465(c)(2)(B), see Venture                 
          Funding, Ltd. v. Commissioner, 110 T.C. 236, 241-242 (1998),                
          affd. without published opinion 198 F.3d 248 (6th Cir. 1999), and           






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