to “debt-financed property.” Similarly, although Taxpayer argues that this Court “held” in Rensselaer Polytechnic, 732 F.2d at 1061, and People’s Educational Camp Society, Inc. v. Commissioner, 331 F.2d 923, 935 (2d Cir.1964), that “the” purpose of the UBIT was the elimination of unfair competition, these cases also do not assist Taxpayer, as both involved undisputed evidence of unfair competition and did not address whether unfair competition must be shown for imposition of the UBIT. Moreover, Taxpayer cites no court of appeals case holding that unfair competition must be shown for imposition of the UBIT, and our review of the applicable case law - reveals that no court of appeals has required such a showing. See, e.g., State Police Ass’n v. Commissioner, 125 F.3d 1, 8 (1st Cir.1997) (<HOLDING>); NCAA, 914 F.2d at 1425 (same); Fraternal
recognizing that a finding of actual physical control does not require that car actually is moving holding that imposition of ubit does not necessarily require showing of actual competition holding that although purchase of securities on margin does not seem to present source of unfair competition both plain meaning of statute and congressional intent support imposition of ubit on this type of income holding that for purposes of rule 9006b the code does not require a showing of extraordinary circumstances holding that the mere fact that the fda does not require a warning on a product label does not necessarily create a conflict