Page:United States Statutes at Large Volume 68A.djvu/167

 CH. 1—NORMAL TAXES AND SURTAXES

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all of the basis in the hands of the acquiring corporation as does not exceed the basis in the hands of the distributor or transferor corporation. (7) P R E P A I D INCOME.—If the acquiring corporation assumes the liability described in section 452(e)(2) with respect to prepaid income of a distributor or transferor corporation which had elected, under section 452(d), to report such income as provided in section 452, the acquiring corporation shall be treated, for this purpose, as if it were the distributor or transferor corporation, unless the acquiring corporation, after the date of distribution or transfer, uses the cash receipts and disbursements method of accounting. In the latter case, the acquiring corporation shall include in gross income for the first taxable year ending after the date of distribution or transfer, so much of such prepaid income as was not includible in gross income of the distributor or transferor corporation under section 452 for preceding taxable years. (8) INSTALLMENT METHOD.—If the acquiring corporation acquires installment obligations (the income from which the distributor or transferor corporation has elected, under section 453, to report on the installment basis) the acquiring corporation shall, for purposes of section 453, be treated as if it were the distributor or transferor corporation. (9) AMORTIZATION OF BOND DISCOUNT OR PREMIUM.—If the

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quiring corporation assumes liability for bonds of the distributor or transferor corporation issued at a discount or premium, the acquiring corporation shall be treated as the distributor or transferor corporation after the date of distribution or transfer for purposes of determining the amount of amortization allowable or includible with respect to such discount or premium. (10) TREATMENT OF CERTAIN EXPENSES DEFERRED BY THE ELECTION OF DISTRIBUTOR OR TRANSFEROR CORPORATION.—The

acquiring corporation shall be entitled to deduct, as if it were the distributor or transferor corporation, expenses deferred under sections 615 and 616 (relating to exploration and development expenditures, respectively) if the distributor or transferor corporation has so elected. For the purpose of applying the limitation provided in section 615, if, for any taxable year, the distributor or transferor corporation was allowed the deduction in section 615(a) or made the election in section 615(b), the acquiring corporation shall be deemed to have been allowed such deduction or to have made such election, as the case may be. (11)

CONTRIBUTIONS TO PENSION PLANS, EMPLOYEES' ANNUITY

PLANS, AND STOCK BONUS AND PROFIT-SHARING PLANS. The acquiring corporation shall be considered to be the distributor or transferor corporation after the date of distribution or transfer for the purpose of determining the amounts deductible under section 404 with respect to pension plans, employees' annuity plans, and stock bonus and profit-sharing plans. (12)

RECOVERY OP BAD DEBTS, PRIOR TAXES, OR DELINQUENCY

AMOUNTS.—If the acquiring corporation is entitled to the recovery of bad debts, prior taxes, or delinquency amounts previously deducted or credited hj the distributor or transferor corporation, the § 381(c) (12)

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