-48- * * * 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), andPage: Previous 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 Next
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