96 T.C. 845, 1991 WL 106265 (1991), aff'd by unpublished opinion, 988 F.2d 120 (9th Cir.1993): We quite agree that Congress was concerned with putting an end to the abuses reflected in Clay Brown and University Hill. But, although it focused on those particular abuses, the provisions which it enacted were couched in broader terms, and were not limited precisely to those situations. This is but another instance of Congress’ going beyond the evil which it seeks to correct in closing a loophole. In the words of Judge Friendly in Commissioner v. Pepsi-Cola Niagara Bottling Corp., 399 F.2d 390, 392 (2d Cir.1968), “a legislature seeking to catch a particular abuse may find it necessary to cast a wider net.” Kern County Elec., 96 T.C. at 853; see also Elliot Knitwear, 614 F.2d at 350 (<HOLDING>). In short, we find no basis for ignoring the
holding that absent unusual circumstances this court must apply the plain meaning of a statute 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 imposition of ubit does not necessarily require showing of actual competition holding securities purchased on margin are subject to ubit as marginfinanced securities are debtfinanced property and  514a requires treating income derived therefrom as income from unrelated trade or business holding that general statement of intent does not override plain language of statute