Page:United States Statutes at Large Volume 100 Part 1.djvu/357

 PUBLIC LAW 99-272—APR. 7, 1986

100 STAT. 321

"(g) SPECIAL RULE FOR CERTAIN SERVICES RELATED TO A I R 26 USC 132 note. TRANSPORTATION.— "(1) IN GENERAL.—If^

"(A) an individual performs services for a qualified air transportation organization, and "(B) such services are performed primarily for persons engaged in providing air transportation and are of the kind which (if performed on September 12, 1984) would qualify such individual for no-additional-cost services in the form of air transportation, then, with respect to such individual, such qualified air transportation organization shall be treated as engaged in the line of business of providing air transportation. "(2) QUALIFIED AIR TRANSPORTATION ORGANIZATION.—For purposes of paragraph (1), the term 'qualified air transportation organization' means any organization— "(A) if such organization (or a predecessor) was in existence on September 12, 1984, "(B) if— "(i) such organization is described in section 501(c)(6) of the Internal Revenue Code of 1954 and the member- 26 USC 501. ship of such organization is limited to entities engaged in the transportation by air of individuals or property for compensation or hire, or "(ii) such organization is a corporation all the stock of which is owned entirely by entities referred to in clause (i), and "(C) if such organization is operated in furtherance of the activities of its members or owners.". SEC. 13208. CERTAIN INSOLVENT TAXPAYERS ALLOWED TO REDUCE CAPITAL GAINS PREFERENCE ITEM FOR PURPOSES OF THE INDIVIDUAL MINIMUM TAX. (a) IN GENERAL.—Paragraph (9) of section 57(a) (relating to capital 26 USC 57. gains as items of tax preference) is amended by adding at the end thereof the following new subparagraph: "(E) SPECIAL RULE FOR CERTAIN INSOLVENT TAXPAYERS.—

"(i) IN GENERAL.—The amount of the tax preference under subparagraph (A) shall be reduced (but not below zero) by the excess (if any) of— "(I) the applicable percentage of gain from any farm insolvency transaction, over "(II) the applicable percentage of any loss from any farm insolvency transaction which offsets such gain. "(ii) REDUCTION LIMITED TO AMOUNT OF INSOLVENCY.—

The amount of the reduction determined under clause (i) shall not exceed the amount by which the taxpayer is insolvent immediately before the transaction (reduced by any portion of such amount previously taken into account under this clause). "(iii) FARM INSOLVENCY TRANSACTION.—For purposes

of this subparagraph, the term 'farm insolvency transaction' means— "(I) the transfer by a farmer of farmland to a creditor in cancellation of indebtedness or

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