argument. Under the plain language of the UBIT, the purchase of securities on margin is a purchase using borrowed funds; therefore, under § 514(c), the securities are subject to an “acquisition indebtedness.” See Elliot Knitwear Profit Sharing Plan v. Commissioner, 614 F.2d 347, 348-51 (3d Cir.1980). Thus, the margin-financed securities constitute “debt-financed property” under § 514(b)(1). As “debt-financed property,” § 512(b)(4) and § 514(a)(1) require that the income derived from these securities be treated “as an item of gross income derived from an unrelated trade or business” (in the proportion that the basis of the property bears to the amount financed), and, therefore, this income is included in the § 512 computation of unrelated business taxable income. See, e.g., id. (<HOLDING>). Thus, Taxpayer’s reliance on Supreme Court
recognizing defense in securities case 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 morrison precludes securities claims brought by us investors who purchase securities on a foreign exchange even where those securities are also listed on a us exchange 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 claims alleging that the debtor fraudulently induced the claimants to retain securities they had purchased from the debtor arise from the purchase or sale of those securities for purposes of  510b