Page:United States Statutes at Large Volume 102 Part 4.djvu/479

 PUBLIC LAW 100-647—NOV. 10, 1988

102 STAT. 3449

(D)(i) Except as provided in clause (ii), the following provisions of section 265(b)(3) of the 1986 Code (as amended by this subparagraph (A)) shall apply to obligations issued after June 30, 1987: a) subparagraph (C)(iiXIH), (II) clauses (ii) and (iii) of subparagraph (D), and (III) subparagraphs (E) and (F). (ii) At the election of an issuer (made at such time and in such manner as the Secretary of the Treasury or his delegate may prescribe), the provisions referred to in clause (i) shall apply to such issuer as if included in the amendments made by section 902(a) of the Tax Reform Act of 1986. (4) Subparagraph (B) of section 291(e)(l) of the 1986 Code is amended by redesignating the clause (iv) added by section 902(c)(2) of the Reform Act as clause (v). (5) Clause (i) of section 291(e)(l)(B) of the 1986 Code is amended by striking out "section 582(a)(2)" and inserting in lieu thereof "section 585(a)(2)". (6) Paragraph (1) of section 902(e) of the Reform Act is 26 USC 163. amended by striking out "Section 163(h)(12)" and inserting in lieu thereof "Section 163(i)(2) (as redesignated by section 511(b) of this Act)". (7) Paragraph (4) of section 902(f) of the Reform Act is 26 USC 265 note. amended— (A) by inserting "and qualified 501(c)(3) bonds designated by such Governor for purposes of this paragraph," after "1987),", and (B) by striking out "subparagraph" in the last sentence and inserting in lieu thereof "paragraph". (c) AMENDMENTS RELATED TO SECTION 903 OF THE REFORM ACT.—

(1) Paragraph (1) of section 172(b) of the 1986 Code is amended by redesignating subparagraphs (L) and (M) as subparagraphs (K) and (L), respectively. (2) Subparagraph (A) of section 172(b)(l) of the 1986 Code is amended by striking out "Except" and all that follows down through "a net operating loss" and inserting in lieu thereof "Except as otherwise provided in this paragraph, a net operating loss". (3) Subparagraph (B) of section 172(b)(l) of the 1986 Code is amended to read as follows: "(B) Except as otherwise provided in this paragraph, a net operating loss for any taxable year ending after December 31, 1975, shall be a net operating loss carryover to each of the 15 taxable years following the taxable year of the loss." (d) AMENDMENTS RELATED TO SECTION 905 OF THE REFORM ACT.—

(1) Subsection G) of section 165 of the 1986 Code is amended by redesignating paragraph (6) as paragraph (7) and by striking out paragraph (5) and inserting in lieu thereof the following: "(5) ELECTION TO TREAT AS ORDINARY LOSS.—

"(A) IN GENERAL.—In lieu of any election under paragraph (1), the taxpayer may elect to treat the amount referred to in paragraph (1) for the taxable year as an ordinary loss described in subsection (c)(2) incurred during the taxable year. "(B) LIMITATIONS.—

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