Page:United States Statutes at Large Volume 98 Part 3.djvu/1085

 CONCURRENT RESOLUTIONS—JUNE 29, 1984

98 STAT. 3457

graph (A)(i) to the first day of such taxable year, or "(ii) any period after the close of the taxable year, such portion shall be assigned under subparagraph (A)(i) to the last day of the taxable year. "(D) TREATMENT OF DEDUCTIBLE ITEMS ATTRIBUTABLE TO

PRIOR PERIODS.—If any portion of a deductible cash basis itemis assigned under subparagraph (C)(i) to the first day of any taxable year— "(i) such portion shall be allocated among persons who are partners in the partnership during the period to which such portion is attributable in accordance with their varying interests in the partnership during such period, and "(ii) any amount allocated under clause (i) to a person who is not a partner in the partnership on such first day shall be capitalized by the partnership and treated in the manner provided for in section 755." (30) In paragraph (5) of section 77(b) of the bill, insert "and which was executed on or before March 31, 1984," after "March 29, 1984,". (31) In section 77(b)(5) of the bill, strike out "on, or before" and insert in lieu thereof "on or before". (32) In section 91(g) of the bill, strike out paragraphs (1) and (2) and insert the following: "(1) IN GENERAL.—Except as provided in this subsection and subsections (h) and (i), the amendments made by this section shall apply to amounts with respect to which a deduction would be allowable under chapter 1 of the Internal Revenue Code of 1954 (determined without regard to such amendments) after— "(A) in the case of amounts to which section 461(h) of such Code (as added by such amendments) applies, the date of the enactment of this Act, and "(B) in the case of amounts to which section 461(i) of such Code (as so added) applies, after March 31, 1984. "(2) TAXPAYER MAY ELECT EARUER APPLICATION.—

"(A) IN GENERAL.—In the case of amounts described in paragraph (I)(A), a taxpayer may elect to have the amendments made by this section apply to amounts which— "(i) are incurred before the date of the enactment of this Act (determined without regard to such amendments), and "(ii) are incurred on or after the date of the enactment of this Act (determined with regard to such amendments). "(B) ELECTION TREATED AS CHANGE IN THE METHOD OF

ACCOUNTING.—For purposes of section 481 of the Internal Revenue Code of 1954, if an election is made under subparagraph (A) with respect to any amount, the application of the amendments made by this section shall be treated as a change in method of accounting— "(i) initiated by the taxpayer, "(ii) made with the consent of the Secretary of the Treasury, and "(iii) with respect to which section 481 of such Code shall be applied by substituting a 3-year adjustment period for a 10-year adjustment period.

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