Page:United States Statutes at Large Volume 98 Part 1.djvu/572

 98 STAT. 524

PUBLIC LAW 98-369—JULY 18, 1984 ^„^,.

(11) SPECIAL RULE FOR CERTAIN PARTNERSHIPS.— (A) PARTNERSHIPS FOR WHICH QUALIFYiNG ACTION

EXISTED BEFORE OCTOBER 21, 1983.—Paragraph (9) of section 168(j) of the Internal Revenue Code of 1954 (as added by this section) shall not apply to any property acquired, directly or indirectly, before January 1, 1985, by any partnership described in subparagraph (B). (B) APPLICATION FILED BEFORE OCTOBER 21, 1983.—A partnership is described in this subparagraph if— (i) before October 21, 1983, the partnership was organized, a request for exemption with respect to such partnership was filed with the Department of Labor, and a private placement memorandum stating the maximum number of units in the partnership that would be offered had been circulated, (ii) the interest in the property to be acquired, directly or indirectly (including through acquiring an interest in another partnership) by such partnership was described in such private placement memorandum, and (iii) the marketing of partnership units in such partnership is completed not later than two years after the .^ jg^^gj. Qf ^j^g jjg^^g Qf ^j^g enactment of this Act or the date of publication in the Federal Register of such r*'?/;w."exemption by the Department of Labor and the aggregate number of units in such partnership sold does not exceed the amount described in clause (i). r

Ante, p. 509.

Mt- Jf;.' V

Federal Register, publication.

(C) PARTNERSHIPS FOR WHICH QUALIFYING ACTION EXISTED

BEFORE MARCH 6, 1984.—Paragraph (9) of section 168(j) of

Ante, p. 509.

'"''* ^^

gf.,,,.

the Internal Revenue Code of 1954 (as added by this section) shall not apply to any property acquired directly or indirectly, before January 1, 1986, by any partnership described in subparagraph (D). For purposes of this subparagraph, property shall be deemed to have been acquired prior to January 1, 1986, if the partnership had entered into a written binding contract to acquire such property prior to January 1, 1986 and the closing of such contract takes place within 6 months of the date of such contract (24 months in the case of new construction). (D) PARTNERSHIP ORGANIZED BEFORE MARCH 6, 1984.—A partnership is described in this subparagraph if— (i) before March 6, 1984, the partnership was organized and publicly announced the maximum amount (as shown in the registration statement, prospectus or partnership agreement, whichever is greater) of interests which would be sold in the partnership, and (ii) the marketing or partnership interests in such partnership was completed not later than the 90th day after the date of the enactment of this Act and the aggregate amount of interest in such partnership sold does not exceed the maximum amount described in clause (i). (12)

SPECIAL RULE

FOR AMENDMENT MADE

BY SUBSECTION

(c)(2).—The amendment made by subsection (c)(2) to the extent it relates to subsection (f)(12) of section 168 of the Internal Revenue Code of 1954 shall take effect as if it had been included

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