-49- we do so mindful of the statute as a whole. We conclude that Congress’s use of the word “any” denotes one (i.e., the same) taxable year and that LCL’s aggregated activities are only those activities that relate to leased personal property placed in service in the same taxable year.9 As we understand petitioners’ contrary interpretation, its effect would be that virtually “all activities [of a partnership or S corporation] with respect to section 1245 properties which * * * are leased or held for lease * * * shall be treated as a single activity.” Petitioners do not explain how that interpretation does not render section 465(c)(2)(B)(i)(II) surplusage, and we are unable to give such an explanation either. Nor do petitioners explain how their interpretation harmonizes with section 465(c)(2)(B)(ii) and, more particularly, the reference in that section to section 465(c)(3)(B). Under petitioners’ interpretation, section 465(c)(2)(B)(ii) also would be surplusage in that all equipment leasing activities of a partnership or S corporation would already be considered to be a single activity under section 465(c)(2)(B)(i). Petitioners’ reliance on the word “any” to reach their interpretation also is misplaced. The word “any” denotes “One, some, every, or all without specification”, The American Heritage 9 By cross-reference from sec. 465(c)(1)(C), sec. 1245(a) provides that the term “section 1245 property” as used in sec. 465 includes personal property.Page: 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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