Page:United States Statutes at Large Volume 107 Part 1.djvu/561

 PUBLIC LAW 103-66—AUG. 10, 1993 107 STAT. 535 "(B) Any right to receive tangible property or services under a contract or granted by a governmental unit or agency or instrumentality thereof. "(C) Any interest in a patent or copjrright. "(D) To the extent provided in regulations, any right under a contract (or granted by a governmental unit or an agency or instrumentality thereof) if such right— "(i) has a fixed duration of less than 15 years, or "(ii) is fixed as to amount and, without regard to this section, would be recoverable under a method similar to the unit-of-production method. "(5) INTERESTS UNDER LEASES AND DEBT INSTRUMENTS.— Any interest under— "(A) an existing lease of tangible property, or "(B) except as provided in subsection (d)(2)(B), any existing indebtedness. "(6) TREATMENT OF SPORTS FRANcmsES. —A firanchise to engage in professional football, basketball, baseball, or other professional sport, and any item acquired in connection with such a franchise. "(7) MORTGAGE SERVICING. — Any right to service indebtedness which is secured by residential real property unless such right is acquired in a transaction (or series of related transactions) involving the acquisition of assets (other than rights described in this paragraph) constituting a trade or business or substantial portion thereof. "(8) CERTAIN TRANSACTION COSTS.—Any fees for professional services, and any transaction costs, incurred by parties to a transaction with respect to which any portion of the gain or loss is not recognized under part III of subchapter C. "(£) SPECIAL RULES. — "(A) IN GENERAL. —If there is a disposition of any amortizable section 197 intangible acquired in a transaction or series of related transactions (or any such intangible becomes worthless) and one or more other amortizable section 197 intangibles acquired in such transaction or series of related transactions are ret£uned— "(i) no loss shall be recognized by reason of such disposition (or such worthlessness), and "(ii) appropriate adjustments to the adjusted bases of such retained intangibles shall be made for any loss not recognized under clause (i). "(B) SPECIAL RULE FOR COVENANTS NOT TO COMPETE. — In the case of any section 197 intangible which is a covenant not to compete (or other arrangement) described in subsection (d)(l)(E), in no event shall such covenant or other arrangement be treated as disposed of (or becoming worthless) before the disposition of the entire interest described in such subsection in connection with which such covenant (or other arrangement) was entered into. "(C) SPECIAL RULE.— All persons treated as a single taxpayer under section 41(f)(l) shall be so treated for purposes of this paragraph. "(2) TREATMENT OF CERTAIN TRANSFERS.—
 * (1) TREATMENT OF CERTAIN DISPOSITIONS, ETC.—

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