Page:United States Statutes at Large Volume 83.djvu/602

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PUBLIC LAW 91-172-DEC. 30, 1969

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[83

STAT.

"SEC. 278. CAPITAL EXPENDITURES INCURRED IN PLANTING AXD np VELOPING CITRUS GROVES. "*" (a) GbrNERAL RULE,—Except as provided in subsection (b) anv amount (allowable as a deduction without regard to this section) which is attributable to the planting, cultivation, maintenance or development of any citrus grove (or part thereof), and which is incurred before the close of the fourth taxable year beginning with the taxable year in which the trees were planted, shall be charged to capital account. For purposes of the preceding sentence, the portion of a citrus grove planted in one taxable year shall be treated separately from the portion of such grove planted in another taxable year. " (b) EXCEPTIONS.—Subsection (a) shall not apply to amounts allowable as deductions (without regard to this section), and attributable to a citrus grove (or part thereof) which was: "(1) replanted after having been lost or damaged (while in the hands of the taxpayer), by reason of freeze, disease, drought, pests or casualty, or " (2) planted or replanted prior to the enactment of this section." (b) CLERICAL AMENDMENT.—The table of sections for such part IX is amended by adding at the end thereof the following new item: "Sec. 278. Capital expenditures incurred in planting and developing citrus groves."

(c) Eri^CTiVE DATE.—The amendments made by this section shall apply to taxable years beginning after December 31, 1969. Subtitle C—Interest SEC. 221. INTEREST. (a) L I M I T A T I O N ON I N T E R E S T DEDUCTION ATTRIBUTABLE TO INVEST-

68A Stat. 46; 26 USC'i63.

]\iENT INDEBTEDNESS.—Section 163 (relating to interest) is amended by redesignating subsection (d) as (e), and by inserting after subsection (c) the following new subsection: "(d)

LIMITATION ON INTEREST ON INVESTMENT INDEBTEDNESS.—

" (1) IN GENERAL.—In the case of a taxpayer other than a corporation, the amount of investment interest (as defined in paragraph (3)(D)) otherwise allowable as a deduction under this chapter shall be limited, in the following order, to— " (A) $25,000 ($12,500, in the case of a separate return by a married individual), plus " (B) the amount of the net investment income (as defined in paragraph (3)(A)), plus " (C) an amount equal to the amount by which the net long-term capital gain exceeds the net short-term capital loss for the taxable year, plus " (D) one-half of the amount by which investment interest exceeds the sum of the amounts described in subparagraphs (A),(B),and(C). . I n the case of a trust, the $25,000 amount specified in subparagraph (A) and in paragraph (2)(A) shall be zero. In determining the amount described in subparagraph (C), only gains and losses attributable to the disposition of property held for investment shall be taken into account. " (2) C A R R Y O V E R OF D I S A L L O W E D INVESTMENT INTEREST.—

"(A) interest interest amount

IN GENERAL.—The amouut of disallowed investment for any taxable year shall be treated as investment paid or accrued in the succeeding taxable year. The of the interest so treated which is allowable as a

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