- 13 - 2057(b)(1)(C)) will be taken into account indicates that no such limitation was intended and therefore that “loan” interests should be taken into account. Petitioners cite the proposition that “where a statute, with reference to one subject contains a given provision, the omission of such provision from a similar statute concerning a related subject is significant to show that a different intention existed”. 2B Singer, Sutherland Statutory Construction, sec. 51.02, at 199-201 (6th ed. 2000); see also United States v. Lamere, 980 F.2d 506, 513 (8th Cir. 1992) (“Where language is included in one section of a statute but omitted in another section of the same statute, it is generally presumed that the disparate inclusion and exclusion * * * [were] done intentionally and purposely.”); Flahertys Arden Bowl, Inc. v. Commissioner, 115 T.C. 269, 274 (2000), affd. 271 F.3d 763 (8th Cir. 2001) (per curiam). Petitioners also note that section 2057 contains a number of references to “any” interest in a qualified family-owned business, suggesting to petitioners that the reference in section 2057(e)(1)(B) to “an” interest is not to be limited to just an “equity” interest. See sec. 2057(e)(2)(A) (“any” interest in a trade or business); id. subpar. (B) (“any” interest in an entity); id. subpar. (C) (“any” interest in a trade or business). We note that no regulations have been promulgated under section 2057.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 NextLast modified: March 27, 2008