Page:United States Statutes at Large Volume 65.djvu/549

 65 STAT.]

PUBLIC LAW 183—OCT. 20, 1951

515

ment may, nevertheless, be made or allowed if claim therefor is filed within one year from such date. I n the case of any taxable year ending before the date of the making by the taxpayer of an election under this paragraph, no interest shall be paid on any overpayment resulting from the application of the provisions of paragraph (3) to such taxable year, and no interest shall be assessed or collected with respect to any amount or any deficiency specified in clause (A), for any period prior to the expiration of six months following the date of the making of such election by the taxpayer." (b) BASIS or RECOVERED PROPERTY.—Section 127(d) (relating to basis of recovered property) is hereby amended to read as follows: "(d)

26 u.^s:a*§ 127(d).

BASIS OF RECOVERED PROPERTY.—

" (1) IN GENERAL.—The unadjusted basis of property recovered in respect of property considered as destroyed or seized under subsection (a) shall be determined under this subsection. Such basis shall be an amount equal to the fair market value of such property, determined as of the date of the recovery, reduced by an amount equal to the excess of the aggregate of such fair market value and the amounts of previous recoveries of money or property in respect of property considered under subsection (a) as destroyed or seized over the aggregate of the allowable deductions in prior taxable years on account of the destruction or seizure of property described in subsection (a), and increased by that portion of the amount of the recovery which under subsection (c) is treated as a recognized gain from the involuntary conversion of property. Upon application of the taxpayer, the aggregate of the bases (determined under the preceding sentence) of any properties recovered in respect of properties considered under subsection (a) as destroyed or seized may be allocated among the properties so recovered in such manner as the Secretary may determine under regulations prescribed by him, and the amounts so allocated to any such property so recovered shall be the unadjusted basis of such property in lieu of the unadjusted basis of such property determined under the preceding sentence.

^nu.p.sn.

"(2) PROPERTY RECOVERED I N TAXABLE YEAR TO WHICH SUBSECTION (c)(3) IS APPLICABLE.—In the case of a taxpayer who has

made an election under the provisions of subsection (c)(5), the basis of property recovered shall be an amount equal to the value at which such property is included in the amount of the recovery under subsection (c)(3)(A) (determined without regard to the last sentence thereof), reduced by such part of the gain under subsection (c)(3)(C) which is not recognized as provided in section 1 1 2 (f). " (c) CREDIT FOR FOREIGN TAXES.—Section 131

(a)

(relating to

allowance of credit for taxes of foreign countries and possessions of the United States) is hereby amended by inserting after "section 102" the following: "and except the additional tax imposed for the taxable year under the provisions of section 127(c)(3)". (d) EFFECTIVE DATES.—The amendments made by this section shall be applicable to taxable years beginning after December 31, 1941.

Ante, p.m. i u. t; a § 131(a).

Ante.p.m.

SEC. 342. DEDUCTION OF EXPENDITURES FOR MINE EXPLORATION. (a)

DEDUCTION OF M I N E EXPLORATION EXPENDITURES.—Section 23

iu^gc'523

(relating to deductions from gross income) is hereby amended by Ante, pp. 485,'486,, adding at the end thereof the following new subsection: "(ff) DEDUCTION OF EXPLORATION EXPENDITURES.—

"(1) IN GENERAL.—In the case of expenditures paid or incurred during the taxable year for the purpose of ascertaining the existence, location, extent, or quality of any deposit of ore or other

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