Page:United States Statutes at Large Volume 96 Part 1.djvu/537

 P U B L I C L A W 9 7 - 2 4 8 — S E P T. 3, 1982

96 S T A T. 4 9 5

(B) APPLICABLE PERCENTAGE.—For purposes of s u b p a r a -

g r a p h (A), the applicable percentage shall be determined in accordance with the following table: "If the taxable year begins in calendar year: 1983 1984 1985 or thereafter

The applicable percentage is: 33Vii 66% 100.".

(3) SPECIAL RULES.— (A) T I M E OF COMPLETION.—Any contract of a tax p a y e r

which would (but for this paragraph) be t r e a t e d as having been completed prior to the first taxable year of such tax p a y e r ending after December 31, 1982, solely by reason of any modification to regulations made under subsection (a)(1), shall be t r e a t e d as having been completed on the first day of such taxable year. (B) AGGREGATION A N D SEVERANCE.—Any contract of a

tax p a y e r which would (but for this paragraph) be treated as having been completed prior to the first taxable year of such tax p a y e r ending after December 31, 1982— (i) solely by reason of any modification to regulations made under subsection (a)(2), or (ii) solely by reason of any modifications to regulations made under both paragraph s (1) and (2) of subsection (a), shall be treated as having been completed on the first d a y after December 31, 1982, on which any contract which w a s severed from such contract (by reason of the modifications made by subsection (a)(2)) is completed (determined after the application of any modifications to regulations made under subsection (a)(1)). SEC. 230. ANNUAL ACCRUAL METHOD OF ACCOUNTING EXTENDED TO CERTAIN PARTNERSHIPS.

(a) IN GENERAL.—Section 447(g) (relating to certain annual accrual accounting methods) is amended— (1) by inserting "or qualified partnership " after "corporation" each place it appears in paragraph (1), (2) by amending paragraph (3) to read as follows: "(3) CERTAIN NONRECOGNITION TRANSFERS.—For purposes of

this subsection, if— "(A) a corporation acquired substantially all the assets of a qualified farming trade or business from a n other corporation in a transaction in which no gain or loss was recognized to the transferor or transferee corporation, or "(B) a qualified partnership acquired substantially all the assets of a qualified farming trade or business from one of its part n e r s in a transaction to which section 721 applies, the transferee corporation or qualified partnership shall be deemed to have computed its taxable income on a n annual accrual method of accounting during the period for which the transferor corporation or partnership computed its taxable income from such trade or business on a n annual accrual method.", and (3) by adding a t the end thereof the following new paragraph: "(4) QUALIFIED PARTNERSHIP DEFINED.—For purposes of t h i s

subsection—

^^ ^SC 447.

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