Page:United States Statutes at Large Volume 100 Part 3.djvu/393

 PUBLIC LAW 99-514—OCT. 22, 1986

100 STAT. 2201

No deduction shall be allowed under this chapter for interest described in subparagraph (B). "(3) ACCELERATED PORTION OF CREDIT.—For purposes of paragraph (2), the accelerated portion of the credit for the prior taxable years with respect to any amount of basis is the excess of— "(A) the aggregate credit allowed by reason of this section (without regard to this subsection) for such years with respect to such basis, over "(B) the aggregate credit which would be allowable by reason of this section for such years with respect to such basis if the aggregate credit which would (but for this subsection) have been allowable for the entire compliance period were allowable ratably over 15 years. "(4) SPECIAL RULES.— "(A) TAX BENEFIT RULE.—The

tax for the taxable year shall be increased under paragraph (1) only with respect to credits allowed by reason of this section which were used to reduce tax liability. In the case of credits not so used to reduce tax liability, the carryforwards and carrybacks under section 39 shall be appropriately adjusted. "(B) ONLY BASIS FOR WHICH CREDIT ALLOWED TAKEN INTO

ACCOUNT.—Qualified basis shall be taken into account under paragraph (1)(B) only to the extent such basis was taken into account in determining the credit under subsection (a) for the preceding taxable year referred to in such paragraph. "(C) No RECAPTURE OF ADDITIONAL CREDIT ALLOWABLE BY REASON OF SUBSECTION (f)(3).—Paragraph (1) shall apply to

a decrease in qualified basis only to the extent such decrease exceeds the amount of qualified basis with respect to which a credit was allowable for the taxable year referred to in paragraph (1)(B) by reason of subsection (0(3). "(D) No CREDITS AGAINST TAX.—Any increase in tax under this subsection shall not be treated as a tax imposed by this chapter for purposes of determining the amount of any credit under subpart A, B, or D of this part. "(E) No RECAPTURE BY REASON OF CASUALTY LOSS.—The

increase in tax under this subsection shall not apply to a reduction in qualified basis by reason of a casualty loss to the extent such loss is restored by reconstruction or replacement within a reasonable period established by the Secretary. "(5) CERTAIN PARTNERSHIPS TREATED AS THE TAXPAYER.—

"(A) IN GENERAL.—For purposes of applying this subsection to a partnership to which this paragraph applies— "(i) such partnership shall be treated as the taxpayer to which the credit allowable under subsection (a) was allowed, "(ii) the amount of such credit allowed shall be treated as the amount which would have been allowed to the partnership were such credit allowable to such partnership, ''(iii) paragraph (4)(A) shall not apply, and "(iv) the amount of the increase in tax under this subsection for any taxable year shall be allocated among the partners of such partnership in the same

�