-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.
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