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          rules] consistent.”  S. Rept. 91-552, supra at 70, 1969-3 C.B. at           
               In sum, the legislative history shows clearly that Congress,           
          in replacing the former exclusion for real property (and                    
          associated personal property) rental activities with the more               
          limited exclusion provided in section 502(b)(1), did so to                  
          preserve consistency between the feeder organization rules and              
          the UBTI rules.  Petitioner’s position, by contrast, assumes that           
          the 1969 legislation introduced inconsistency, where it did not             
          exist before, between the feeder organization rules and the UBTI            
          rules.  In the light of the legislative history, as well as the             
          plain meaning of the statute and the regulations, petitioner’s              
          position is untenable.                                                      
               4.  Does the Section 502(b)(1) Exclusion Apply?                        
               Alternatively, petitioner argues that even if its rental               
          activity is deemed to be a “trade or business” under section                
          502(a), it qualifies for the section 502(b)(1) exclusion.  As               
          previously noted, section 502(b)(1) excludes from the definition            
          of “trade or business” the deriving of rents “which would be                
          excluded under section 512(b)(3), if section 512 applied to the             
          organization”.  Petitioner contends, and respondent does not                
          dispute, that petitioner’s rents would be excluded under section            
          512(b)(3) if that provision were applied in isolation.                      
          Petitioner does not dispute that its rentals, deriving from debt-           

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