Page:United States Statutes at Large Volume 96 Part 2.djvu/366

 96 STAT. 1728

26 USC 172.

Ante, p. 1727.

PUBLIC LAW 97-362—OCT. 25, 1982

"(I) a net operating loss carryback to each of the 3 taxable years preceding the taxable year of the loss, and "(II) a net operating loss carryover to each of the 15 taxable years following the taxable year of the loss." (b) RULES RELATING TO F N M A MORTGAGE DISPOSITION Loss.— Section 172 is amended by redesignating subsections (i) and (j) as subsections (j) and (k), respectively, and by inserting after subsection (h) the following new subsection: "(i) RULES RELATING TO FNMA MORTGAGE DISPOSITION Loss.— "(1) FNMA MORTGAGE DISPOSITION LOSS DEFINED.— "(A) IN GENERAL.—For puiposes of subsection (b)(1)(H) and this subsection, the term FNMA mortgage disposition loss' means for any taxable year the excess (if any) of— "(i) the losses for such year from the sale or exchange of mortgages, securities, and other evidences of indebtedness, over "(ii) the gains for such year from the sale or exchange of such assets. "(B) FNMA MORTGAGE DISPOSITION LOSS CANNOT EXCEED THE NET OPERATING LOSS FOR THE YEAR.—The a m o U n to f the

FNMA mortgage disposition loss for any taxable year shall not be greater than the net operating loss for such year. "(C) FORECLOSURE TRANSACTIONS NOT INCLUDED.—In ap-

plying subparagraph (A), any gain or loss which is attributable to a mortgage foreclosure shall not be taken into account. "(2) COORDINATION WITH SUBSECTION (b)(2).—In applying paragraph (2) of subsection (b), a FNMA mortgage disposition loss shall be treated in a manner similar to the manner in which a foreign expropriation loss is treated." (c) CONFORMING AMENDMENTS.—

(1) Subparagraph (A) of section 172(b)(l) is amended by striking out "(H), and (1)" and inserting in lieu thereof "(H), (I), and (J)^'. (2) Subparagraph (B) of section 172(b)(l) is amended by striking out and (I) in the second sentence and inserting in lieu thereof "(H), and (J)". (3) Subparagraph (I) of section 172(b)(l), as redesignated by subsection (a), is amended by striking out "subsection (i)" and inserting in lieu thereof "subsection (j)". (4) Paragraph (3) of section 172(j), as redesignated by subsection (b), is amended by striking out "subsection (b)(l)(H)" each place it appears and inserting in lieu thereof "subsection (b)(l)(D". 26 USC 172 note. (d) EFFECTIVE DATE.—The amendments made by this section shall apply to net operating losses for taxable years beginning after December 31, 1981. SEC. 103. ROLLOVER OF GAIN ON CERTAIN SALES UNDER FCC ORDER WHERE NEWSPAPERS ARE BOUGHT. If— (1) a corporation was ordered by the Federal Communications Commission in January 1975 to divest itself of its newspaper operations or its broadcasting operations,

�