S.Rep. No. 81-2375 at 28 (1950); H.R.Rep. No. 81-2319 at 36 (1950)); United States v. American Bar Endowment, 477 U.S. 105, 114, 106 S.Ct. 2426, 91 L.Ed.2d 89 (1986); American College of Physicians, 475 U.S. at 837-38, 106 S.Ct. 1591. Although Taxpayer argues that Portland Golf, American Bar Endowment, and American College of Physicians “overruled” Clarence LaBelle’s determination that the elimination of unfair competition was not the “sole” purpose of the UBIT, we find these cases unavailing to Taxpayer, as the Supreme Court did not hold in these cases that unfair competition must be shown for imposition of the UBIT, particularly as appli of Police, Illinois State Troopers, Lodge No. II v. Commissioner, 833 F.2d 717, 722-23 (7th Cir.1987) (same); Clarence LaBelle, 580 F.2d at 272 (<HOLDING>). Taxpayer also argues that the “mischief rule”
holding that actual competition is only one factor to be considered in imposing ubit recognizing that the governments failure to prevail is a factor that may be considered holding that factor 10 should not be applied when the victim is the only one at risk holding that edwards protection only extends to interrogation and that denial of counsel is only one factor to be considered in determining whether  consent was voluntarily given but it is not a decisive fact holding that no one factor is determinative and the weakness of one factor may be overborne by the strength of the others