-50-
Dictionary of the English Language 81 (4th ed. 2000), and
Congress’s use of the word “any” “can and does mean different
things depending upon the setting”, Nixon v. Mo. Municipal
League, 541 U.S. 125, 132 (2004). In this setting, we simply do
not understand Congress’s use of that word to establish its
intent that section 465(c)(2)(B)(i) allow LCL to treat all of its
equipment leasing activities as a single activity regardless of
the year in which the equipment was placed in service. The fact
that Congress prescribed in the statute the singular form of the
word “year” adds to our belief.
While the legislative history underlying the enactment of
section 465(c)(2)(B) as applied to section 1245 properties is
sparse and of little benefit to our inquiry, see H. Conf. Rept.
98-861, at 1122 (1984), 1984-3 C.B. (Vol.2) 1, 376, we believe
that the setting surrounding the enactment of section
465(c)(2)(B) also is consistent with our conclusion. Section
465(c)(2) was enacted as part of the Deficit Reduction Act of
1984 (DEFRA), Pub. L. 98-369, sec. 432(b), 98 Stat. 814, which
changed the aggregation rules for partnerships and S corporations
with respect to equipment leasing activities (as well as the
other activities listed in section 465(c)(1)) for taxable years
beginning after December 31, 1983. Before DEFRA, partnerships
and S corporations aggregated all activities within each of five
specified categories for purposes of section 465. Thus, a
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