# Pub. L. 97-248: changes to the Internal Revenue Code 1982-09-03, 96 Stat. 419. Source: . ## Legislative history - Bill: [H.R. 4961](https://www.congress.gov/bill/97th-congress/house-bill/4961) ## § 5: Cross references relating to tax on individuals - § 5(a)(4): Pub. L. 97–248, § 201(d)(4), formerly § 201(c)(4), substituted “section 55” for “sections 55 and 56”. ## § 31: Tax withheld on wages - § 31: Pub. L. 97–248, as amended by Pub. L. 97–354 and Pub. L. 97–448, amended section generally, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983. Section 102(a), (b) of Pub. L. 98–67, title I, Aug. 5, 1983, 97 Stat. 369, repealed subtitle A (§§ 301–308) of title III of Pub. L. 97–248 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 [now 1986] [this title] shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. ## § 46: Amount of credit - § 46: Pub. L. 97–248, § 205(b)(1), substituted “85 percent” for “the following percentage”, substituted a period for the colon, and struck out table of percentages at end of subpar. (B). - § 46: Pub. L. 97–248, §§ 201(d)(8)(A), formerly 201(c)(8)(A), 265(b)(2)(A), substituted “(relating to corporate minimum tax)” for “(relating to minimum tax for tax preferences)” after “section 56”, and inserted “section 72(q)(1) (relating to 5-percent tax on premature distributions under annuity contracts),” after “owner-employees)”. - § 46: Pub. L. 97–248, § 205(b)(2), redesignated par. (9) as (7), and, in par. (7)(B), as so redesignated, substituted reference to 85 percent for former reference to the percentage determined under subsec. (a)(3)(B) in cl. (i), struck out former cl. (ii), which provided that pars. (7) and (8) would not apply in certain instances, and redesignated former cl. (iii) as (ii). Former par. (7), which provided for alternative limitations in the case of certain utilities, was struck out. - § 46: Pub. L. 97–248, § 205(b)(2)(A), struck out par. (8) which provided for alternative limitations in the case of certain railroads and airlines. - § 46: Pub. L. 97–248, § 205(b)(2)(A), redesignated par. (9) as (7). ## § 47: Rehabilitation credit - § 47(a): Pub. L. 97–248, § 208(a)(2)(B), inserted provision that if, prior to a disposition to which this subsection applies, any portion of any credit is not allowable with respect to any property by reason of section 168(i)(3), such portion shall be treated, for purposes of this subparagraph, as not having been used to reduce tax liability. ## § 48: Energy credit - § 48(b): Pub. L. 97–248, § 209(c), inserted provision that for purposes of determining whether section 38 property subject to a lease is new section 38 property, such property shall be treated as originally placed in service not earlier than the date such property is used under the lease, but only if such property is leased within 3 months after such property is placed in service. - § 48(d): Pub. L. 97–248, § 205(a)(4), added par. (5). - § 48: Pub. L. 97–248, § 205(a)(5)(A), struck out par. (5) which, as amended by § 102(f)(3) of Pub. L. 97–448, had provided that for purposes of this subtitle, if a credit were determined under section 46(a)(2) for any qualified rehabilitation expenditure in connection with a qualified rehabilitated building other than a certified historic structure, the increase in basis of such property which would (but for this paragraph) have resulted from such expenditure had to be reduced by the amount of the credit so determined, that if during any taxable year there was a recapture amount determined with respect to any qualified rehabilitated building the basis of which was reduced under subpar. (A), the basis of such building (immediately before the event resulting in such recapture), had to be increased by an amount equal to such recapture amount, and that for purposes of this paragraph “recapture amount” was defined as any increase in tax (or adjustment in carrybacks or carryovers) determined under section 47(a)(5). See 1983 Amendment note for subsec. (g)(5) above and see Effective Date of 1982 and 1983 Amendment notes set out under sections 1 and 196 of this title. - § 48: Pub. L. 97–248, § 205(a)(1), added subsec. (q) and redesignated former subsec. (q) as (r). ## § 51: Amount of credit - § 51(c)(3): Pub. L. 97–248, § 233(a), substituted “1984” for “1982”. - § 51(d)(1)(J): Pub. L. 97–248, § 233(b)(3), added subpar. (J). - § 51(d)(6)(B)(i): Pub. L. 97–248, § 233(d), substituted “consists of money payments or voucher or scrip, and” for “consists of money payments”. - § 51(d)(10): Pub. L. 97–248, § 233(c), inserted provision respecting nonapplicability of paragraph to individuals who begin work for the employer after December 31, 1982. - § 51(d)(12), § 51(d)(13), § 51(d)(14), § 51(d)(15): Pub. L. 97–248, § 233(b)(4), (5), added par. (12) and redesignated former pars. (12) to (15) as (13) to (16), respectively. - § 51(d): Pub. L. 97–248, § 233(b)(4), redesignated former par. (15) as (16). - § 51(d): Pub. L. 97–248, § 233(f), substituted “on or before” for “before” in subpar. (A). ## § 72: Annuities; certain proceeds of endowment and life insurance contracts - § 72(e): Pub. L. 97–248, § 265(a), in par. (1) substituted provisions relating to the application of this subsection to amounts received under annuity, endowment, or life insurance contracts which are not received as annuities and to amounts received as dividends for provisions which stated a general rule relating to the includability as gross income of amounts that were received under annuity, endowment, or life insurance contracts which were not received as annuities and also stated that for the purposes of this section amounts which were received as dividends would be treated as amounts not received as an annuity, in par. (2) substituted provisions stating a general rule as to the includability as gross income of amounts received before or after the annuity starting date for provisions which set out those amounts which would be treated as amounts not received as an annuity, and added pars. (3) to (6). - § 72(m)(4): Pub. L. 97–248, § 236(b)(1), struck out par. (4) which related to amounts constructively received with respect to assignments or pledges, and loans on contracts. - § 72(m)(5): Pub. L. 97–248, § 237(d)(1), (2), in subpar. (A) substituted applicability to key employees for applicability to owner-employees and added subpar. (C). - § 72(m)(6): Pub. L. 97–248, § 237(d)(3), struck out “except in applying paragraph (5),” after “shall”. - § 72(m)(8): Pub. L. 97–248, § 236(b)(1), struck out par. (8) which related to loans to owner-employees. - § 72(o)(3)(A): Pub. L. 97–248, § 236(b)(2), substituted reference to subsec. (p) of this section for references to subsec. (m)(4) and (8) of this section. - § 72(p): Pub. L. 97–248, § 236(a), added subsec. (p). Former subsec. (p) redesignated (q). - § 72(q): Pub. L. 97–248, § 265(b)(1), added subsec. (q). Former subsec. (q) redesignated (r). - § 72(q): Pub. L. 97–248, § 236(a), redesignated former subsec. (p) as (q). - § 72(r): Pub. L. 97–248, §§ 236(a), 265(b)(1), redesignated former subsec. (p) as (r). ## § 79: Group-term life insurance purchased for employees - § 79(d): Pub. L. 97–248 added subsec. (d). ## § 85: Unemployment compensation - § 85(b): Pub. L. 97–248, § 611(a)(1), substituted “$12,000” for “$20,000”. - § 85(b): Pub. L. 97–248, § 611(a)(2), substituted “$18,000” for “$25,000”. ## § 101: Certain death benefits - § 101(a)(1): Pub. L. 97–248, § 266(b), substituted “, subsection (d), and subsection (f)” for “and in subsection (d)”. - § 101(b): Pub. L. 97–248, § 239, amended par. (3) generally, substituting “Treatment of self-employed individuals” for “Self-employed individual not considered an employee” in heading, designating existing provisions as subparagraph (A) and, as so designated, adding heading and exception for subpar. (B), and adding subparagraph (B). - § 101(f): Pub. L. 97–248, § 266(a), added subsec. (f). ## § 103: Interest on State and local bonds - § 103(b)(2): Pub. L. 97–248, § 215(b)(2), substituted “For purposes of this section” for “For purposes of this subsection”. - § 103(b): Pub. L. 97–248, §§ 217(a)(1), (b), 221(a), (c)(1), 310(c)(1), in subpar. (A) substituted “if at all times during the qualified project period” for “if each obligation issued pursuant to the issue is in registered form and if” after “residential rental property”, and struck out “(within the meaning of section 167(k)(3)(B))” after “low or moderate income”, added subpar. (J), struck out provision that for purposes of subpar. (A), “targeted area project” meant a project located in a qualified census tract (within the meaning of section 103A(k)(2)) or an area of chronic economic distress (within the meaning of section 103A(k)(3)) and, in last sentence, substituted “electric energy or gas from” for “electric energy from”. - § 103(b): Pub. L. 97–248, § 217(a)(3), substituted “paragraph (13)” for “paragraph (7)”. - § 103(b): Pub. L. 97–248, § 214(d), added cl. (iv). - § 103(b): Pub. L. 97–248, § 214(a)–(c), (e), added subpars. (K) to (O). - § 103(b): Pub. L. 97–248, § 217(c), inserted “ferry,” after “rail car” in provisions preceding cl. (i), and in cl. (ii), inserted “(or, in the case of a ferry, mass transportation services)” after “mass commuting services”. - § 103(b): Pub. L. 97–248, § 217(a)(2), added par. (10). Former par. (10) redesignated (13). - § 103(b): Pub. L. 97–248, § 217(d), added par. (11). - § 103(b): Pub. L. 97–248, § 221(b), added par. (12). [Provisions of par. (12)(A) were formerly contained, as undesignated provisions, in par. (4).] - § 103(b): Pub. L. 97–248, § 217(a)(2), redesignated former par. (10) as (13). - § 103(b): Pub. L. 97–248, § 219(a), added par. (14). - § 103: Pub. L. 97–248, § 310(c)(2), substituted “must not be guaranteed or subsidized” for “must be in registered form and not guaranteed or subsidized” in heading, and in par. (1) struck out subpar. (A) reading “such obligation is not issued in registered form”, and redesignated subpars. (B) and (C) as (A) and (B), respectively. - § 103: Pub. L. 97–248, § 310(b)(1), added subsec. (j). Former subsec. (j), relating to cross references, redesignated (m). - § 103: Pub. L. 97–248, § 215(a), added subsec. (k). - § 103: Pub. L. 97–248, § 215(b)(1), added subsec. (l). - § 103: Pub. L. 97–248, §§ 215(a), (b)(1), 310(b)(1), redesignated former subsec. (j), relating to cross references, as (m). ## § 105: Amounts received under accident and health plans - § 105(b): Pub. L. 97–248 substituted “section 213(d)” for “section 213(e)”. ## § 162: Trade or business expenses - § 162(c)(1): Pub. L. 97–248, § 288(a), substituted “is unlawful under the Foreign Corrupt Practices Act of 1977” for “would be unlawful under the laws of the United States if such laws were applicable to such payment and to such official or employee” after “government, the payment”, and “(or is unlawful under the Foreign Corrupt Practices Act of 1977)” for “(or would be unlawful under the laws of the United States)” before “shall be upon the Secretary”. - § 162(h): Pub. L. 97–248, § 128(b)(2), redesignated subsec. (i), relating to State legislators’ travel expenses away from home, as (h). Former subsec. (h), relating to group health plans, redesignated (i). - § 162(i): Pub. L. 97–248, § 128(b)(2), redesignated former subsec. (h), relating to group health plans, as (i). Former subsec. (i), relating to State legislators’ travel expenses away from home, redesignated (h). Former subsec. (i), relating to cross references, redesignated (j). - § 162(j): Pub. L. 97–248, § 128(b)(1), redesignated former subsec. (i), relating to cross references, as (j). ## § 163: Interest - § 163(e): Pub. L. 97–248, § 231(b), added subsec. (e) relating to original issue discount. Former subsec. (e), setting forth cross references, redesignated (f). - § 163(e): Pub. L. 97–248, § 231(b), redesignated former subsec. (e), setting forth cross references, as (f). - § 163(f): Pub. L. 97–248, § 310(b)(2), added subsec. (f) relating to the requirement that obligations be in registered form to be tax-exempt. Former subsec. (f), setting forth cross references, redesignated (g). - § 163(g): Pub. L. 97–248, § 310(b)(2), redesignated former subsec. (f), setting forth cross references, as (g). ## § 165: Losses - § 165(c)(3): Pub. L. 97–248, § 203(b), inserted “except as provided in subsection (h),” before “losses of property” and struck out provisions that a loss described in this paragraph would be allowed only to the extent that the amount of loss to such individual arising from each casualty, or from each theft, exceeded $100, that, for purposes of the $100 limitation, a husband and wife making a joint return under section 6013 for the taxable year in which the loss was allowed as a deduction would be treated as one individual, and that no loss described in this paragraph would be allowed if, at the time of filing the return, such loss had been claimed for estate tax purposes in the estate tax return. - § 165(h): Pub. L. 97–248, § 203(a), added subsec. (h) relating to casualty and theft losses. Former subsec. (h), relating to disaster losses, redesignated (i). - § 165(i): Pub. L. 97–248, § 203(a), redesignated former subsec. (h), relating to disaster losses, as (i), in subsec. (i), as so redesignated, further redesignated existing unnumbered provisions as pars. (1) and (2), in par. (1), as so redesignated, substituted “be taken into account for the taxable year” for “be deducted for the taxable year”, in par. (2), as so redesignated, substituted “shall be treated for purposes of this title as having occurred” for “will be deemed to have occurred”, added par. (3), and struck out provision that a deduction under this subsection could not be in excess of so much of the loss as would have been deductible in the taxable year in which the casualty occurred, based on facts existing at the date the taxpayer claimed the loss. Former subsec. (i), setting forth cross references, redesignated (j). - § 165(j): Pub. L. 97–248, § 310(b)(5), added subsec. (j) relating to denial of deduction for losses on certain obligations not in registered form. Former subsec. (j), setting forth cross references, redesignated (k). - § 165(j): Pub. L. 97–248, § 203(a), redesignated former subsec. (i), setting forth cross references, as (j). - § 165(k): Pub. L. 97–248, § 310(b)(5), redesignated former subsec. (j), setting forth cross references, as (k). ## § 168: Accelerated cost recovery system - § 168(b)(1): Pub. L. 97–248, § 206(a), substituted “table” for “tables” in introductory provisions, struck out designation “(A)” preceding the table and struck out subpar. (A) heading which had limited the application of the table to property placed in service after Dec. 31, 1980, and before Jan. 1, 1985, and struck out subpars. (B) and (C), which had provided tables, respectively, for property placed in service in 1985 and for property placed in service after Dec. 31, 1985. - § 168(e)(4): Pub. L. 97–248, §§ 206(b), 224(c)(1), substituted “1981” for “1986” in heading, in subpar. (E) inserted provision that a similar rule shall apply in the case of a deemed liquidation under section 338, and struck out former subpar. (H) which had provided for special rules for property placed in service before certain percentages took effect. - § 168(f): Pub. L. 97–248, § 209(a), amended par. (8) generally, substituting provisions relating to special rules for finance leases for provisions relating to special rule for leases. - § 168(f): Pub. L. 97–248, § 208(a)(2)(A), inserted “except as provided in subsection (i),” before “for purposes of this subtitle”. - § 168(f): Pub. L. 97–248, § 208(b)(1), inserted “which is not a related person with respect to the lessee”. - § 168(f): Pub. L. 97–248, § 208(b)(2), in subcl. (I) substituted “120 percent of the present class life of the property, or” for “90 percent of the useful life of such property for purposes of section 167, or”, and in subcl. II substituted “the period equal to the recovery period determined with respect to such property under subsection (i)(2)” for “150 percent of the present class life of such property”. - § 168(f): Pub. L. 97–248, § 208(b)(3), amended subpar. (D) generally. Prior to amendment, subpar. (D) read as follows: - § 168(f): Pub. L. 97–248, § 208(b)(4), added subpars. (H) to (J) and redesignated former subpar. (H) as (K). - § 168(f): Pub. L. 97–248, § 224(c)(2), struck out “(other than a transaction with respect to which the basis is determined under section 334(b)(2))” after “section 332”. - § 168(f): Pub. L. 97–248, § 216(a), added par. (12). - § 168(i): Pub. L. 97–248, § 209(b), amended subsec. (i) generally, substituting provisions concerning limitations relating to leases of finance lease property for provisions concerning limitations relating to lease of qualified leased property. - § 168(i): Pub. L. 97–248, § 208(a)(1), added subsec. (i). Former subsec. (i) redesignated (j). - § 168(j): Pub. L. 97–248, § 208(a)(1), redesignated former subsec. (i) as (j). ## § 170: Charitable, etc., contributions and gifts - § 170(c)(2): Pub. L. 97–248 inserted provision that rules similar to the rules of section 501(j) of this title shall apply for purposes of this paragraph. ## § 173: Circulation expenditures - § 173: Pub. L. 97–248, § 201(d)(9)(A), designated existing provisions as subsec. (a), added subsec. (a) heading, and added subsec. (b). ## § 174: Amortization of research and experimental expenditures - § 174: Pub. L. 97–248, § 201(d)(9)(B), substituted “Cross references” for “Cross reference” in heading, designated existing provisions as par. (1), and added par. (2). ## § 196: Deduction for certain unused business credits - Enacted 26 U.S.C. § 196. ## § 213: Medical, dental, etc., expenses - § 213(a): Pub. L. 97–248, § 202(a), substituted provisions that there shall be allowed as a deduction the expenses paid during the taxable year, not compensated for by insurance or otherwise, for medical care of the taxpayer, his spouse, or a dependent (as defined in section 152), to the extent that such expenses exceed 5 percent of adjusted gross income, for provision allowing as deductions the amount by which the amount of the expenses paid during the taxable year (reduced by any amount deductible under paragraph (2)) for medical care of the taxpayer, his spouse, and dependents (as defined in section 152) exceeded 3 percent of the adjusted gross income, and an amount (not in excess of $150) equal to one-half of the expenses paid during the taxable year for insurance which constituted medical care for the taxpayer, his spouse, and dependents. - § 213(b): Pub. L. 97–248, § 202(b)(1), amended subsec. (b) generally, substituting provision that an amount paid during the taxable year for medicine or a drug shall be taken into account under subsec. (a) only if such medicine or drug is a prescribed drug or is insulin for former provision that amounts paid during the taxable year for medicine and drugs which (but for this subsection) would have been taken into account in computing the deduction under subsec. (a) would be taken into account only to the extent that the aggregate of such amounts exceeded 1 percent of the adjusted gross income. - § 213(c): Pub. L. 97–248, § 202(b)(3)(B), redesignated subsec. (d) as (c). Former subsec. (c) was repealed by Pub. L. 89–97. - § 213(d): Pub. L. 97–248, § 202(b)(2), (3)(A), (B), redesignated subsec. (e) as (d), added pars. (2) and (3), and redesignated former pars. (2), (3), and (4) as (4), (5), and (6), respectively. Former subsec. (d) redesignated (c). - § 213(e), § 213: Pub. L. 97–248, § 202(b)(3)(B), redesignated subsecs. (e) and (f) as (d) and (e), respectively. ## § 219: Retirement savings - § 219(d)(4): Pub. L. 97–248 added par. (4). ## § 246: Rules applying to deductions for dividends received - § 246: Pub. L. 97–248 added subsec. (e) and redesignated former subsec. (e) as (f). ## § 263: Capital expenditures - § 263(c): Pub. L. 97–248, § 204(c)(1), inserted provision that this subsection not apply with respect to any costs to which any deduction is allowed under section 58(i) or 291. ## § 269A: Personal service corporations formed or availed of to avoid or evade income tax - Enacted 26 U.S.C. § 269A. ## § 274: Disallowance of certain entertainment, etc., expenses - § 274(e)(3): Pub. L. 97–248 provided that, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983, par. (3) is amended by inserting “subchapter A of” before “chapter 24”. Section 102(a), (b) of Pub. L. 98–67, title I, Aug. 5, 1983, 97 Stat. 369, repealed subtitle A (§§ 301–308) of title III of Pub. L. 97–248 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 [now 1986] [this title] shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. ## § 275: Certain taxes - § 275(a)(1): Pub. L. 97–248 provided that, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983, par. (1) is amended by striking out “and” at end of subpar. (B), by substituting “; and” for the period at end of subpar. (C), and by inserting subpar. (D) relating to the tax withheld at source on interest, dividends, and patronage dividends under section 3451. Section 102(a), (b) of Pub. L. 98–67, title I, Aug. 5, 1983, 97 Stat. 369, repealed subtitle A (§§ 301–308) of title III of Pub. L. 97–248 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 [now 1986] [this title] shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. ## § 280E: Expenditures in connection with the illegal sale of drugs - Enacted 26 U.S.C. § 280E. ## § 291: Special rules relating to corporate preference items - Enacted 26 U.S.C. § 291. ## § 302: Distributions in redemption of stock - § 302(a): Pub. L. 97–248, § 222(c)(3), substituted “paragraph (1), (2), (3), or (4)” for “paragraph (1), (2), or (3)”. - § 302(b)(4), § 302(b)(5): Pub. L. 97–248, § 222(c)(1), (4), added par. (4), redesignated former par. (4) as (5) and substituted “paragraph (2), (3), or (4)” for “paragraph (2) or (3)” after “to meet the requirements of”, and “paragraph (1), (2), or (4)” for “paragraph (1) or (2)” after “and also the requirements of”. - § 302(c)(2)(C): Pub. L. 97–248, § 228(a), added subpar. (C). - § 302(e), § 302(f): Pub. L. 97–248, § 222(c)(2), added subsec. (e) and redesignated former subsec. (e) as (f). ## § 304: Redemption through use of related corporations - § 304(b)(2)(A): Pub. L. 97–248, § 226(a)(3), substituted “as if the property were distributed by the issuing corporation to the acquiring corporation and immediately thereafter distributed by the acquiring corporation” for “soley by reference to the earnings and profits of the acquiring corporation” after “dividend shall be made”. - § 304(b)(3): Pub. L. 97–248, § 226(a)(1)(A), added par. (3). - § 304(c)(2), § 304(c)(3): Pub. L. 97–248, § 226(a)(2), added par. (2), redesignated former par. (2) as (3) and substituted “this section” for “paragraph (1)” after “determining control under”. ## § 306: Dispositions of certain stock - § 306(b)(1)(B): Pub. L. 97–248, § 222(e)(2), substituted “paragraph (3) or (4) of section 302(b)” for “section 302(b)(3)”. - § 306(b)(2): Pub. L. 97–248, § 222(e)(1)(A), struck out “partial or” before “complete liquidation”. - § 306(c)(3): Pub. L. 97–248, § 226(b), added par. (3). - § 306(c)(4): Pub. L. 97–248, § 227(a), added par. (4). ## § 311: Taxability of corporation on distribution - § 311: Pub. L. 97–248, § 223(a)(1), substituted reference to a distribution to a corporate shareholder if the basis of the property distributed is determined under section 301(d)(2) for reference to a distribution in complete redemption of all of the stock of a shareholder who, at all times within the 12-month period ending on the date of such distribution owned at least 10 percent in value of the outstanding stock of the distributing corporation, but only if the redemption qualified under section 302(b)(3) (determined without the application of section 302(c)(2)(A)(ii)). - § 311: Pub. L. 97–248, § 223(a)(1), substituted reference to a distribution to which section 302(b)(4) applies and which is made with respect to qualified stock for reference to a distribution of stock or an obligation of a corporation, which was engaged in at least one trade or business, which had not received property constituting a substantial part of its assets from the distributing corporation, in a transaction to which section 351 applied or as a contribution to capital, within the 5-year period ending on the date of the distribution, and at least 50 percent in value of the outstanding stock of which was owned by the distributing corporation at any time within the 9-year period ending one year before the date of the distribution. - § 311: Pub. L. 97–248, § 223(a)(1), substituted reference to a distribution of stock or an obligation of a corporation if the requirements of subsec. (e)(2) of this section are met with respect to the distribution for reference to a distribution of stock or securities pursuant to the terms of a final judgment rendered by a court with respect to the distributing corporation in a court proceeding under the Sherman Act (15 U.S.C. 1–7) or the Clayton Act (15 U.S.C. 12–27), or both, to which the United States was a party, but only if the distribution of such stock or securities in redemption of the distributing corporation’s stock was in furtherance of the purposes of the judgment. - § 311: Pub. L. 97–248, § 223(a)(3), struck out subpar. (G) which provided that a distribution of stock to a distributee which is not an organization exempt from tax under section 501(a) of this title, if with respect to such distributee, subsec. (a)(1) or (b)(1) of section 1101 of this title applied to such distribution. - § 311: Pub. L. 97–248, § 223(a)(2), added subsec. (e). ## § 312: Effect on earnings and profits - § 312(e): Pub. L. 97–248, § 222(e)(3), struck out “partial liquidations and” in heading, and in text struck out “in partial liquidation (whether before, on, or after June 22, 1954) or” after “amounts distributed”. - § 312(k)(5): Pub. L. 97–248, § 205(a)(3), added par. (5). - § 312(m): Pub. L. 97–248, § 310(b)(3), added subsec. (m). ## § 318: Constructive ownership of stock - § 318(b)(4): Pub. L. 97–248 substituted “section 338(h)(3)(B) (relating to purchase of stock from subsidiaries, etc.)” for “section 334(b)(3)(C) (relating to basis of property received in certain liquidations of subsidiaries)”. ## § 331: Gain or loss to shareholder in corporate liquidations - § 331(a): Pub. L. 97–248, § 222(a), substituted provisions that amounts received by a shareholder in a distribution in complete liquidation of a corporation shall be treated as in full payment in exchange for the stock for provisions that, in complete liquidations, amounts distributed shall be treated as in full payment in exchange for the stock, while amounts distributed in partial liquidation shall be treated as in part or full payment in exchange for the stock. - § 331(b): Pub. L. 97–248, § 222(e)(1)(B), struck out “partial or” before “complete liquidation”. ## § 334: Basis of property received in liquidations - § 334(a): Pub. L. 97–248, § 222(e)(1)(C), struck out “partial or” before “complete liquidation”. - § 334(b): Pub. L. 97–248, § 224(b), struck out heading to par. (1) “In general”, redesignated first sentence as par. (1) with heading “Distribution in complete liquidation”, in par. (1) as so redesignated substituted reference to section 332(a) for reference to section 332(b) relating to a distribution in complete liquidation, struck out reference to par. (2) as an exception to the determination of basis, redesignated second sentence as par. (2) with heading “Transfers to which section 332(c) applies”, in par. (2) as so redesignated struck out reference to par. (2) as an exception to the determination of basis, struck out par. (2) which had provided that if property was received by a corporation in a distribution in complete liquidation of another corporation and if the distribution was pursuant to a plan of liquidation adopted not more than 2 years after the date of the transaction described below, or in the case of a series of transactions, the date of the last such transaction, and stock of the distributing corporation possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote, and at least 80 percent of the total number of shares of all other classes of stock (except nonvoting stock which was limited and preferred as to dividends), was acquired by the distributee by purchase (as defined in par. (3)) during a 12-month period beginning with the earlier of the date of the first acquisition by purchase of such stock, or if any of such stock was acquired in an acquisition which is a purchase within the meaning of second sentence of par. (3), the date on which the distributee was first considered under section 318(a) as owning stock owned by the corporation from which such acquisition was made, then the basis of the property in the hands of the distributee would be the adjusted basis of the stock with respect to which the distribution was made, and under regulations prescribed by the Secretary, proper adjustment in the adjusted basis of any stock would be made for any distribution made to the distributee with respect to such stock before the adoption of the plan of liquidation, for any money received, for any liabilities assumed or subject to which the property was received, and for other items, and struck out par. (3) which provided that “purchase” meant any acquisition of stock, but only if the basis of the stock in the hands of the distributee was not determined in whole or in part by reference to the adjusted basis of such stock in the hands of the person from whom acquired, or under section 1014(a) of this title the stock was not acquired in an exchange to which section 351 of this title applies, and the stock was not acquired from a person the ownership of whose stock would, under section 318(a) of this title, be attributed to the person acquiring such stock, but that “purchase” also meant an acquisition of stock from a corporation when ownership of such stock would be attributed under section 318(a) to the person acquiring such stock, if the stock of such corporation by reason of which such ownership would be attributed was acquired by purchase, and redesignated par. (4) as (3). ## § 338: Certain stock purchases treated as asset acquisitions - Enacted 26 U.S.C. § 338. ## § 346: Definition and special rule - § 346(a): Pub. L. 97–248 substituted provision that a distribution shall be treated as in complete liquidation if the distribution is one of a series in redemption of all the stock pursuant to a plan for provision that a distribution was to be treated as in partial liquidation if the distribution was one of a series in redemption of all the stock pursuant to a plan, or the distribution was not essentially equivalent to a dividend, was in redemption of part of the stock pursuant to a plan, and occurred within the taxable year or the next taxable year of the plan being adopted, including but not limited to a distribution which met the requirements of former subsec. (b) of this section, and that for the purposes of sections 562(b) and 6043 of this title, a partial liquidation included a redemption of stock to which section 302 of this title applied. - § 346(b): Pub. L. 97–248 added subsec. (b) and struck out former subsec. (b) which provided that a distribution was to be treated as in partial liquidation of a corporation if the distribution was attributable to the cessation of a business which had been carried on for the previous 5-year period and had not been acquired by the corporation in a transaction involving recognition of gain or loss during that time, and if the distributing corporation was actively involved in a trade or business immediately after the distribution under the terms described above for the business being liquidated, and that compliance with the above requirements would be determined without regard to whether or not the distribution was pro rata with respect to all the shareholders of the corporation. - § 346: Pub. L. 97–248 struck out subsec. (c) which provided that the fact that, with respect to a shareholder, a distribution qualified under section 302(a) by reason of section 302(b) would not be taken into account in determining whether the distribution, with respect to such shareholder, was also a distribution in partial liquidation of the corporation. ## § 351: Transfer to corporation controlled by transferor - § 351(f): Pub. L. 97–248 added par. (5). ## § 356: Receipt of additional consideration - § 356(a)(2): Pub. L. 97–248 inserted “(determined with the application of section 318(a))” after “distribution of a dividend”. ## § 367: Foreign corporations - § 367(d), § 367(e): Pub. L. 97–248 added subsec. (d) and redesignated former subsec. (d) as (e). ## § 368: Definitions relating to corporate reorganizations - § 368(a)(1)(F): Pub. L. 97–248 inserted “of one corporation” after “place of organization”. ## § 381: Carryovers in certain corporate acquisitions - § 381(a)(1): Pub. L. 97–248 struck out “, except in a case in which the basis of the assets distributed is determined under section 334(b)(2)” after “applies”. ## § 401: Qualified pension, profit-sharing, and stock bonus plans - § 401(a)(9): Pub. L. 97–248, § 242(a), which was repealed by Pub. L. 98–369, § 521(a)(2), had amended par. (9) generally, redesignating existing provisions as subpar. (A), in subpar. (A), as so redesignated, struck out preliminary provision which limited the application of this paragraph to plans providing contributions or benefits for employees some or all of whom were employees within the meaning of subsec. (c)(1), redesignated former subpars. (A) and (B) as cls. (i) and (ii) of subpar. (A), in cl. (i), as so redesignated, substituted reference to a key employee who is a participant in a top-heavy plan for former reference to owner-employees (within the meaning of subsec. (c)(3)), redesignated former cls. (i) and (ii) of subpar. (B) as subcls. (I) and (II) of cl. (ii), struck out former provision that a trust would not be disqualified under this paragraph by reason of distributions under a designation, prior to the date of the enactment of this paragraph, by any employee under the plan of which such trust was a part, of a method of distribution which did not meet the terms of this paragraph, and adding subpar. (B). - § 401(a)(10): Pub. L. 97–248, § 237(e)(1), amended par. (10) generally, redesignating subpar. (B) as (A) and striking out former subpar. (A) relating to qualified trust as a trust forming part of such plan, for provisions relating to discriminatory plans with respect to nonapplicability of paragraph (3), the first and second sentences of paragraph (5) and section 410 of this title. - § 401(a)(10)(B): Pub. L. 97–248, § 240(b), added subpar. (B). - § 401(a)(17), § 401(a)(18): Pub. L. 97–248, § 237(b), struck out pars. (17) and (18) which related, respectively, to a plan which provides contributions or benefits for employees some or all of whom are employees within the meaning of subsection (c)(1), or are shareholder-employees within the meaning of section 1379(d), and a trust which is part of a plan providing a defined benefit for employees some or all of whom are employees within the meaning of subsection (c)(1), or are shareholder-employees within the meaning of section 1379(d). - § 401(a)(24): Pub. L. 97–248 added par. (24). - § 401(c)(1): Pub. L. 97–248, § 238(d)(1), amended par. (1) generally, substituting in heading “Self-employed individual treated as employee” for “Employee”, adding subparagraph headings, and substituting provisions defining “employee” and “self-employed individual”, for provisions defining “employee”. - § 401(c)(2)(A): Pub. L. 97–248, § 238(d)(2), added cl. (v). - § 401(d): Pub. L. 97–248, § 237(a), redesignated pars. (9) to (11) as (1) to (3), respectively. Former pars. (1) to (7), which related to trusts created or organized before or after October 10, 1962, contributions under the plan, benefits under the plan for employees, contributions or benefits under the plan, limitations pursuant to the plan, applicability of requirements of subsec. (a)(4) of this section, and distributions under the plan, respectively, were struck out. - § 401(j): Pub. L. 97–248, § 238(b), struck out subsec. (j) which related to general requirements, regulation guidelines, applicable percentage, certain contributions and benefits not taken into account, definitions, and special rules with respect to defined benefit plans providing benefits for self-employed individuals and shareholder-employees. - § 401(l), § 401(o): Pub. L. 97–248, § 249(a), added subsec. (l) and redesignated former subsec. (l) as (o). ## § 403: Taxation of employee annuities - § 403(b)(2): Pub. L. 97–248, § 251(a)(1), (c)(3), substituted “home health service agencies, and certain churches, etc.” for “and home health service agencies”, and “(under section 415 without regard to section 415(c)(8))” for “(under section 415)”. - § 403(b)(2): Pub. L. 97–248, § 251(a)(2), added subpars. (C) and (D). - § 403(b)(9): Pub. L. 97–248, § 251(b), added par. (9). ## § 404: Deduction for contributions of an employer to an employees’ trust or annuity plan and compensation under a deferred-payment plan - § 404(a)(2): Pub. L. 97–248, § 237(e)(2), substituted “(8), (9)” for “(8)”, and “401(a)(10) and of section 401(d)” for “401(a)(9), (10), (17), and (18) and of section 401(d) (other than paragraph (1))”. - § 404(a)(3)(B): Pub. L. 97–248, § 253(b), inserted provision that “compensation otherwise paid or accrued during the taxable year to all employees” shall include any amount with respect to which an election under section 415(c)(3)(C) is in effect, but only to the extent that any contribution with respect to such amount is nonforfeitable. - § 404(e): Pub. L. 97–248, § 238(a), amended subsec. (e) generally, substituting provisions relating to contributions allocable to life insurance protection for self-employed individuals, for provisions relating to general requirements, contributions made under more than one plan, contributions allocable to insurance protection, and limitations of not lower than $750 or 100 percent of earned income with respect to special limitations for self-employed individuals. - § 404(j): Pub. L. 97–248, § 235(f), added subsec. (j). ## § 408: Individual retirement accounts - § 408(a)(2): Pub. L. 97–248, § 237(e)(3)(A), substituted reference to subsection (n) of this section, for reference to section 401(d)(1). - § 408(a): Pub. L. 97–248, § 243(a)(1), amended par. (7) generally, designating existing provisions as subpars. (A) and (B), in subpar. (B), as so designated, striking out “if” before “distribution”, in provisions following subpar. (B) substituting “will be distributed within 5 years after his death (or the death of the surviving spouse)” for “will, within 5 years after his death (or the death of the surviving spouse), be distributed, or applied to the purchase of an immediate annuity for his beneficiary or beneficiaries (or the beneficiary or beneficiaries of his surviving spouse) which will be payable for the life of such beneficiary or beneficiaries (or for a term certain not extending beyond the life expectancy of such beneficiary or beneficiaries) and which annuity will be immediately distributed to such beneficiary or beneficiaries”, and substituting “shall not apply” for “does not apply”. - § 408(b)(4): Pub. L. 97–248, § 243(a)(2), amended par. (4) generally, designating existing provisions, as subpars. (A) and (B), in subpar. (B), as so redesignated, striking out “if” before “distribution”, in provisions following subpar. (B) substituting “will be distributed within 5 years after his death (or the death of the surviving spouse)” for “will, within 5 years after his death (or the death of the surviving spouse), be distributed, or applied to the purchase of an immediate annuity for his beneficiary or beneficiaries (or the beneficiary or beneficiaries of his surviving spouse) which will be payable for the life of such beneficiary or beneficiaries (or for a term certain not extending beyond the life expectancy of such beneficiary or beneficiaries) and which annuity will be immediately distributed to such beneficiary or beneficiaries”, and substituting “shall not apply” for “shall have no application”. - § 408(d)(3)(C): Pub. L. 97–248, § 243(b)(1)(A), added subpar. (C) relating to denial of rollover treatment for inherited accounts. - § 408(d)(3)(C): Pub. L. 97–248, § 335(a)(1), added subpar. (C) relating to permitting partial rollovers. - § 408(j): Pub. L. 97–248, § 238(d)(3), amended subsec. (j) generally, substituting provisions increasing amount by the amount of the limitation in effect under section 415(c)(1)(A), for provisions increasing amount by substituting “$15,000” for “$2,000”. - § 408(k)(1): Pub. L. 97–248, § 238(d)(4)(B), struck out reference to par. (6) of this subsection. - § 408(k)(3)(C): Pub. L. 97–248, § 238(d)(4)(C), amended subpar. (C) generally, striking out cl. “(i)” designation and cl. (ii) which related to taking into account compensation in excess of $100,000 with respect to a simplified employee pension. - § 408(k)(6): Pub. L. 97–248, § 238(d)(4)(A), struck out par. (6) which related to prohibition on employer maintaining plan to which section 401(j) applies. - § 408(n), § 408(o): Pub. L. 97–248, § 237(e)(3)(B), added subsec. (n) and redesignated former subsec. (n) as (o). ## § 414: Definitions and special rules - § 414(b), § 414(c): Pub. L. 97–248, § 240(c)(1), inserted reference to section 416. - § 414(m)(4)(B): Pub. L. 97–248, § 240(c)(2), inserted reference to section 416. - § 414(m)(5), § 414(m)(6), § 414(m): Pub. L. 97–248, § 246(a), added par. (5) and redesignated former pars. (5) and (6) as (6) and (7), respectively. - § 414(n): Pub. L. 97–248, § 248(a), added subsec. (n). ## § 415: Limitations on benefits and contribution under qualified plans - § 415(b)(1)(A): Pub. L. 97–248, § 235(a)(1), substituted “$90,000” for “$75,000”. - § 415(b)(2)(C): Pub. L. 97–248, § 235(a)(3)(A), (e)(1), (2), inserted provisions relating to reduction under this subparagraph, and substituted “$90,000” for “$75,000” and “62” for “55”, wherever appearing. - § 415(b)(2)(D), § 415(b)(2)(E): Pub. L. 97–248, § 235(e)(3), (4), added subpars. (D) and (E). - § 415(b)(7): Pub. L. 97–248, § 235(a)(3)(B), substituted “the greater of $68,212 or one-half the amount otherwise applicable for such year under paragraph (1)(A) for ‘$90,000’ ” for “ ‘37,500’ for ‘75,000’ ”. - § 415(c)(1)(A): Pub. L. 97–248, § 235(a)(2), substituted “$30,000” for “$25,000”. - § 415(c)(3): Pub. L. 97–248, § 253(a), designated existing provisions as subpars. (A) and (B) and added subpar. (C). - § 415(c)(4): Pub. L. 97–248, § 251(c)(1), substituted “, home health service agencies, and certain churches, etc.” for “and home health service agencies” in heading, in subpar. (A) inserted “(as determined for purposes of section 403(b)(2))” after “by taking into account his service for the employer”, substituted “a home health service agency, or a church, convention or association of churches, or an organization described in section 414(e)(3)(B)(ii)” for “or a home health service agency” in subpars. (A), (B) and (C), respectively, and, in subpar. (D), added cl. (iv). - § 415(c)(5): Pub. L. 97–248, § 238(d)(5), struck out par. (5) relating to application with section 404(e)(4). - § 415(c)(8): Pub. L. 97–248, § 251(c)(2), added par. (8). - § 415(d)(1): Pub. L. 97–248, § 235(b)(1), substituted “benefit amounts” for “primary insurance amounts” in provision following subpar. (C). - § 415(d)(1): Pub. L. 97–248, § 235(b)(3), substituted “$90,000” for “$75,000” in subpar. (A), and in subpar. (B) substituted “$30,000” for “$25,000”. - § 415(d)(2)(A): Pub. L. 97–248, § 235(b)(2)(B), substituted “1984” for “1974”. - § 415(d)(3): Pub. L. 97–248, § 235(b)(2)(A), added par. (3). - § 415(e): Pub. L. 97–248, § 235(c)(1), substituted “1.0” for “1.4”. - § 415(e): Pub. L. 97–248, § 235(c)(2)(A), substituted provisions that for purposes of this subsection, the defined benefit plan fraction for any year has a denominator which is the lesser of the product of 1.25 multiplied by the dollar limitation in effect under subsec. (b)(1)(A) for such year, or the product of 1.4 multiplied by the amount which may be taken into account under subsec. (b)(1)(B) with respect to such individual under the plan for such year, for provisions that such benefit plan fraction had a denominator which was the projected annual benefit of the participant under the plan (determined as of the close of the year) if the plan provided the maximum benefit allowable under subsec. (b). - § 415(e): Pub. L. 97–248, § 235(c)(2)(B), substituted provision that the defined contribution plan fraction for any year has a denominator which, determined for such year and for each prior year of service with the employer, is the lesser of either the product of 1.25 multiplied by the dollar limitation in effect under subsec. (c)(1)(A) for such year (determined without regard to subsec. (c)(6)), or the product of 1.4 multiplied by the amount which may be taken into account under subsec. (c)(1)(B) (or subsec. (c)(7) or (8), if applicable) with respect to such individual under such plan for such year, for provision that the denominator of such fraction was the sum of the maximum amount of annual additions to the participant’s account which could have been made under subsec. (c) for such year and for each prior year of service with the employer (determined without regard to subsec. (c)(6)). - § 415(e): Pub. L. 97–248, § 235(d), added par. (6). ## § 416: Special rules for top-heavy plans - Enacted 26 U.S.C. § 416. ## § 447: Method of accounting for corporations engaged in farming - § 447: Pub. L. 97–248, § 230(a)(1), inserted “or qualified partnership” after “corporation” wherever appearing. - § 447: Pub. L. 97–248, § 230(a)(2), designated existing provisions from “a corporation acquired” through “transferee corporation”, as subpar. (A), inserted “qualified” before “farming trade”, and added subpar. (B). - § 447: Pub. L. 97–248, § 230(a)(3), added par. (4). ## § 501: Exemption from tax on corporations, certain trusts, etc. - § 501(c)(19): Pub. L. 97–248, § 354(a)(1), substituted “past or present members of the Armed Forces of the United States” for “war veterans” after “A post or organization of”. - § 501(c)(19)(B): Pub. L. 97–248, § 354(a)(2), substituted “past or present members of the Armed Forces of the United States” for “war veterans” wherever appearing, struck out “veterans (but not war veterans), or are” after “individuals who are”, and substituted “or of cadets” for “or such individuals” before “, and”. - § 501(c)(23): Pub. L. 97–248, § 354(b), added par. (23). - § 501(j), § 501(k): Pub. L. 97–248, § 286(a), added subsec. (j) and redesignated former subsec. (j) as (k). ## § 511: Imposition of tax on unrelated business income of charitable, etc., organizations - § 511: Pub. L. 97–248 substituted “section 55” for “section 55 and section 56 (as the case may be)”. ## § 542: Definition of personal holding company - § 542(c)(6)(C)(ii): Pub. L. 97–248, § 293(a), struck out “but not $1,000,000” after “exceeds $500,000”. - § 542(d)(1)(B)(i): Pub. L. 97–248, § 293(b), substituted “144 months” for “60 months” after “remaining maturity exceeds”, designated existing provisions from “the loans” through “transferor’s trade or business, or” as subcl. (I), and added subcl. (II). - § 542(d)(1)(C): Pub. L. 97–248, § 293(c), added subpar. (C). ## § 543: Personal holding company income - § 543: (a)(1)(C). Pub. L. 97–248 added subpar. (C). ## § 562: Rules applicable in determining dividends eligible for dividends paid deduction - § 562(b)(1): Pub. L. 97–248 inserted sentence at end providing that, for purposes of subpar. (A), a liquidation includes a redemption of stock to which section 302 applies. ## § 616: Development expenditures - § 616(d): Pub. L. 97–248 added subsec. (d). ## § 617: Deduction and recapture of certain mining exploration expenditures - § 617(h): Pub. L. 97–248, § 224(c)(8), inserted “338,” after “334(b),”. - § 617: Pub. L. 97–248, § 201(d)(9)(D), formerly § 201(c)(9)(D), added subsec. (j). ## § 643: Definitions applicable to subparts A, B, C, and D - § 643(d): Pub. L. 97–248 provided that, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983, this section is amended by adding subsec. (d) relating to coordination with withholding on interest and dividends. Section 102(a), (b) of Pub. L. 98–67, title I, Aug. 5, 1983, 97 Stat. 369, repealed subtitle A (§§ 301–308) of title III of Pub. L. 97–248 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 (this title) shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. ## § 661: Deduction for estates and trusts accumulating income or distributing corpus - § 661(a): Pub. L. 97–248 provided that, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983, subsec. (a) is amended by inserting at end “For purposes of paragraph (1), the amount of distributable net income shall be computed without the deduction allowed by section 642(c).”. Section 102(a), (b) of Pub. L. 98–67, title I, Aug. 5, 1983, 97 Stat. 369, repealed subtitle A (§§ 301–308) of title III of Pub. L. 97–248 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 (this title) shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. ## § 702: Income and credits of partner - § 702(d): Pub. L. 97–248 added subsec. (d). ## § 832: Insurance company taxable income - § 832(e)(2): Pub. L. 97–248 struck out “, as if no election to make installment payments under section 6152 is made” after “due to be paid”. ## § 897: Disposition of investment in United States real property - § 897(a)(2)(A): Pub. L. 97–248 substituted “section 55(a)(1) for the taxable year shall not be less than 20 percent of the lesser of—” for “section 55(a)(1)(A) for the taxable year shall not be less than 20 percent of whichever of the following is the least:” in introductory provisions, in cl. (i) struck out “(1)” after “section 55(b)” and inserted “or” at the end, in cl. (ii) substituted a period for a comma and struck out “or” at the end, and struck out former cl. (iii), which had provided for the amount of $60,000 as a third alternative. ## § 901: Taxes of foreign countries and of possessions of United States - § 901(a): Pub. L. 97–248 substituted “(relating to corporate minimum tax)” for “(relating to minimum tax for tax preferences)” after “section 56”, and inserted “section 72(q)(1) (relating to 5-percent tax on premature distributions under annuity contracts),” after “owner employees)”. ## § 904: Limitation on credit - § 904(f)(4), § 904(f)(5), § 904(f): Pub. L. 97–248 struck out par. (4) which provided for the determination of foreign oil related loss where section 907 was applicable, redesignated par. (5) as (4), and purported to redesignate par. (6) as (5). However, subsec. (f) did not contain a par. (6). ## § 905: Applicable rules - § 905(c): Pub. L. 97–248, § 343(a), struck out provision that, although no interest can be assessed or collected on any amount of tax due on any redetermination by the Secretary, resulting from a refund to the taxpayer, for any period before the receipt of such refund, except to the extent interest has been paid by the foreign country or possession of the United States on such refund for such period, that prohibition does not apply (with respect to any period after the refund or adjustment in the foreign taxes) if the taxpayer fails to notify the Secretary (on or before the date prescribed by regulations for giving such notice) unless it is shown that such failure is due to reasonable cause and not due to willful neglect. ## § 907: Special rules in case of foreign oil and gas income - § 907(b): Pub. L. 97–248, § 211(c)(1), added subsec. (b). Former subsec. (b), which had provided that section 904 be applied separately with respect to foreign oil related income and other taxable income, was struck out. - § 907(c)(2): Pub. L. 97–248, § 211(b), in subpar. (A) substituted “the processing of minerals extracted (by the taxpayer or by any other person) from oil or gas wells into their primary products” for “the extraction (by the taxpayer or any other person) of minerals from oil or gas wells”, deleted subpar. (B) which had provided that foreign oil related income meant the taxable income derived from sources outside the United States and its possessions from the processing of minerals from oil or gas wells into their primary products, redesignated subpar. (C) as (B), redesignated subpar. (D) as (C) and in subpar. (C) as so redesignated struck out “or” at the end, redesignated subpar. (E) as (D) and in subpar. (D) as so redesignated substituted “disposition” for “sale or exchange”, and “or (C), or” for “(C), or (D)”, struck out the period at the end, and added subpar. (E). - § 907(c)(4): Pub. L. 97–248, § 211(a), substituted provisions regarding the recapture of foreign oil and gas extraction losses by recharacterization of later extraction income for provisions that if, for any foreign country for any taxable year, the taxpayer would have had a net operating loss if only items from sources within such country (including deductions properly apportioned or allocated thereto) which related to the extraction of minerals from oil or gas wells had been taken into account, such items would not be taken into account in computing foreign oil and gas extraction income for such year, but would be taken into account in computing foreign oil related income for such year. - § 907(e): Pub. L. 97–248, § 211(d)(1), substituted rules regarding credits arising in taxable years beginning before Jan. 1, 1983, for rules regarding taxable years ending after Dec. 31, 1974, in par. (1), and in par. (2) substituted rules regarding carryback of credits arising in taxable years beginning after Dec. 31, 1982, for rules regarding taxable years ending after Dec. 31, 1975. - § 907(f)(1): Pub. L. 97–248, § 211(d)(2)(A), substituted “such excess” for “so much of such excess as does not exceed 2 percent of foreign oil and gas extraction income for such taxable year” in first sentence, and struck out former provision that had directed that the above substitution be made regarding taxes deemed paid or accrued in any taxable year which ended in 1975, 1976, or 1977. - § 907(f)(2)(B): Pub. L. 97–248, § 211(d)(2)(B)(i), substituted “provided by section 904 for such taxable year” for “provided by section 904 on taxes paid or accrued with respect to foreign oil-related income for such taxable year” in the introductory provisions, and in cl. (i) substituted “the United States during such taxable year” for “the United States with respect to such income during such taxable year”. - § 907(f)(3)(A): Pub. L. 97–248, § 211(d)(2)(B)(ii), substituted “section 904(c)” for “section 904(c) with respect to oil-related income”. - § 907(f)(3)(B): Pub. L. 97–248, § 211(d)(2)(B)(iii), struck out “oil-related” after “determining the amount of”. ## § 934: Limitation on reduction in income tax liability incurred to the Virgin Islands - § 934(b)(2): Pub. L. 97–248, § 213(b)(1), substituted “65 percent” for “50 percent”. - § 934: Pub. L. 97–248, § 213(b)(2), added subsec. (e). - § 934: Pub. L. 97–248, § 213(b)(2), added a temporary subsec. (f) which provided that in applying subsec. (b)(2) with respect to taxable years beginning after December 31, 1982, and before January 1, 1985, “55 percent” shall be substituted for “65 percent” for taxable years beginning in calendar year 1983 and “60 percent” shall be substituted for “65 percent” for taxable years beginning in calendar year 1984. ## § 952: Subpart F income defined - § 952(a): Pub. L. 97–248 inserted provision that the payments referred to in par. (4) are payments which would be unlawful under the Foreign Corrupt Practices Act of 1977 if the payor were a United States person. ## § 954: Foreign base company income - § 954(a): Pub. L. 97–248, § 212(a), (e), added par. (5). - § 954(b)(4): Pub. L. 97–248, § 212(d), inserted at end “The preceding sentence shall not apply to foreign base company oil related income described in subsection (a)(5).” - § 954(b)(5): Pub. L. 97–248, § 212(b)(1), substituted “, the foreign base company shipping income, and the foreign base company oil related income” for “and the foreign base company shipping income”. - § 954(b): Pub. L. 97–248, § 212(b)(2), added par. (8). - § 954(h): Pub. L. 97–248, § 212(c), added subsec. (h). ## § 964: Miscellaneous provisions - § 964(a): Pub. L. 97–248 inserted provision that payments referred to in sentence beginning “In determining such earnings and profits” are payments which would be unlawful under the Foreign Corrupt Practices Act of 1977 if the payor were a United States person. ## § 982: Admissibility of documentation maintained in foreign countries - Enacted 26 U.S.C. § 982. ## § 1016: Adjustments to basis - § 1016(a)(24): Pub. L. 97–248, § 205(a)(5)(B), substituted “to the extent provided in section 48(q)” for “to the extent provided in section 48(g)(5)”. - § 1016(a)(25): Pub. L. 97–248, § 201(c)(2), added par. (25). ## § 1402: Definitions - § 1402(b): Pub. L. 97–248 struck out “and” before “(B)” and inserted “, and (C) includes, but only with respect to the tax imposed by section 1401(b), remuneration paid for medicare qualified Federal employment (as defined in section 3121(u)(2)) which is subject to the taxes imposed by sections 3101(b) and 3111(b)”. ## § 1561: Limitation on accumulated earnings credit in the case of certain controlled corporations - § 1561(a): Pub. L. 97–248, § 259(b), added par. (4) and inserted reference to par. (4) in text following par. (4). - § 1561(b): Pub. L. 97–248, § 259(c), added par. (4) and inserted reference to subsec. (a)(4) in text following par. (4). ## § 2039: Annuities - § 2039: Pub. L. 97–248, § 245(b), substituted “Subject to the limitation of subsection (g), notwithstanding any other provision of this section” for “Notwithstanding the provisions of this section”. - § 2039: Pub. L. 97–248, § 245(b), substituted “Subject to the limitation of subsection (g), notwithstanding any other provision of this section” for “Notwithstanding the provisions of this section”. - § 2039: Pub. L. 97–248, § 245(a), added subsec. (g). ## § 2055: Transfers for public, charitable, and religious uses - § 2055(a): Pub. L. 97–248 inserted provision that rules similar to the rules of section 501(j) of this title shall apply for purposes of par. (2). ## § 2522: Charitable and similar gifts - § 2522(a): Pub. L. 97–248 inserted provision that rules similar to rules of section 501(j) apply for purposes of par. (2). ## § 3121: Definitions - § 3121(u): Pub. L. 97–248 added subsec. (u). ## § 3122: Federal service - § 3122: Pub. L. 97–248 inserted “including service which is medicare qualified Federal employment (as defined in section 3121(u)(2)),”. ## § 3301: Rate of tax - § 3301: Pub. L. 97–248, § 271(c)(1)(A), substituted “6.2 percent” for “3.5 percent”. - § 3301: Pub. L. 97–248, § 271(b)(1), substituted “3.5 percent” for “3.4 percent”. - § 3301: Pub. L. 97–248, § 271(c)(1)(B), substituted “6.0 percent” for “3.2 percent”. ## § 3302: Credits against tax - § 3302(b): Pub. L. 97–248, § 271(c)(2)(A), substituted “5.4 percent” for “2.7 percent”. - § 3302(c)(2): Pub. L. 97–248, § 273(a), inserted provision at end that subpar. (C) shall not apply with respect to any taxable year to which it would otherwise apply (but that subpar. (B) would apply to such taxable year) if the Secretary of Labor determines (on or before Nov. 10 of such taxable year) that the State meets the requirements of subsec. (f)(2)(B) of this section for such taxable year. - § 3302(c)(2)(A): Pub. L. 97–248, § 271(c)(3)(A), substituted “5 percent” for “10 percent” in two places. - § 3302(c)(3): Pub. L. 97–248, § 271(c)(3)(B), substituted “7½ percent” for “15 percent” in provisions following subpar. (B). - § 3302(d)(1): Pub. L. 97–248, § 271(c)(2)(B), substituted “6 percent” for “3 percent” in par. heading and text. - § 3302(g): Pub. L. 97–248, § 272(a), added subsec. (g). ## § 3304: Approval of State laws - § 3304(a)(6)(A)(ii): Pub. L. 97–248 redesignated existing provisions as provisions preceding subcl. (I) and subcl. (I), and in such provisions as so redesignated, struck out “(other than an institution of higher education)” after “capacity for an educational institution”, substituted “2” for “two”, and inserted “except that” at end of subcl. (I), and added subcl. (II). ## § 3306: Definitions - § 3306(b)(1): Pub. L. 97–248, § 271(a), substituted “$7,000” for “$6,000” wherever appearing. - § 3306(c)(1)(B): Pub. L. 97–248, § 277, substituted “1984” for “1982”. - § 3306(c)(10)(C): Pub. L. 97–248, § 276(a)(1), struck out “under the age of 22” after “service performed by an individual”. - § 3306(c)(20): Pub. L. 97–248, § 276(b)(1), added par. (20). - § 3306(q): Pub. L. 97–248, § 276(b)(2), added subsec. (q). ## § 3402: Income tax collected at source - § 3402(o)(6): Pub. L. 97–248, § 334(d), added par. (6). - § 3402(s): Pub. L. 97–248, § 317(a), added subsec. (s). ## § 3403: Liability for tax - § 3403: Pub. L. 97–248 provided that, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983, this section is amended by striking out “this chapter” and inserting in lieu thereof “this subchapter”. Section 102(a), (b) of Pub. L. 98–67, title I, Aug. 5, 1983, 97 Stat. 369, repealed subtitle A (§§ 301–308) of title III of Pub. L. 97–248 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 [now 1986] [this title] shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. ## § 3405: Special rules for pensions, annuities, and certain other deferred income - Enacted 26 U.S.C. § 3405. ## § 3502: Nondeductibility of taxes in computing taxable income - § 3502(b), § 3502: Pub. L. 97–248 provided that, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983, subsec. (b) is amended and a new subsec. (c) is added. Section 102(a), (b) of Pub. L. 98–67, title I, Aug. 5, 1983, 97 Stat. 369, repealed subtitle A (§§ 301–308) of title III of Pub. L. 97–248 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 [now 1986] [this title] shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. ## § 3508: Treatment of real estate agents and direct­ sellers - Enacted 26 U.S.C. § 3508. ## § 3509: Determination of employer’s liability for certain employment taxes - Enacted 26 U.S.C. § 3509. ## § 4041: Imposition of tax - § 4041(c): Pub. L. 97–248, § 279(a), in par. (1) substituted “14 cents” for “7 cents”, in par. (3) substituted “8 cents a gallon (10½ cents a gallon in the case of any gasoline with respect to which a tax is imposed under section 4081 at the rate set forth in subsection (b) thereof)” for “3 cents a gallon”, and in par. (5) substituted provisions that the taxes imposed by pars. (1) and (2) shall apply during the period beginning on Sept. 1, 1982, and ending on Dec. 31, 1987, for provisions that on and after Oct. 1, 1980, the taxes imposed by pars. (1) and (2) would not apply. - § 4041(l): Pub. L. 97–248, § 279(b)(1), added subsec. (l). ## § 4251: Imposition of tax - § 4251(a): Pub. L. 97–248 added subsec. (a) and struck out former subsec. (a) which provided that there was a tax on communication services specified as local telephone service, toll telephone service, and teletypewriter exchange service, directed that the tax was to be paid by the person paying for such services, and designated the tax as the percentage of the amount paid for the services as set out in the following table: - § 4251(b): Pub. L. 97–248 added subsec. (b) and struck out former subsec. (b) which provided that the tax imposed by former subsec. (a) would not apply to amounts paid pursuant to bills first rendered on or after January 1, 1985. ## § 4261: Imposition of tax - § 4261(e): Pub. L. 97–248 substituted provisions relating to exemptions for certain helicopter uses for provisions that effective with respect to transportation beginning after Sept. 30, 1980, the rate of taxes imposed by subsecs. (a) and (b) would be 5 percent and taxes imposed by subsec. (c) would not apply. - § 4261(f): Pub. L. 97–248 added subsec. (f). ## § 4262: Definition of taxable transportation - § 4262(c)(3): Pub. L. 97–248, § 281A(a)(1), substituted “12 hours” for “6 hours” wherever appearing. - § 4262(e): Pub. L. 97–248, § 281A(a)(2), added subsec. (e). ## § 4271: Imposition of tax - § 4271(d): Pub. L. 97–248 substituted provision that the tax imposed by subsec. (a) shall apply with respect to transportation beginning after Aug. 31, 1982, and before Jan. 1, 1988, for provision that effective with respect to transportation beginning after Sept. 30, 1980, the tax imposed by subsec. (a) would not apply. ## § 4281: Small aircraft on nonestablished lines - § 4281: Pub. L. 97–248 struck out “(as defined in section 4492(b))” after “certificated takeoff weight”, and inserted provision defining “maximum certificated takeoff weight”. ## § 4701: Tax on issuer of registration-required obligation not in registered form - Enacted 26 U.S.C. § 4701. ## § 5701: Rate of tax - § 5701(b)(1): Pub. L. 97–248, § 283(a)(1), substituted “$8” for “$4”. - § 5701(b)(2): Pub. L. 97–248, § 283(a)(2), substituted “$16.80” for “$8.40”. ## § 6001: Notice or regulations requiring records, statements, and special returns - § 6001: Pub. L. 97–248 inserted “, records necessary to comply with section 6053(c),” after “charge receipts”. ## § 6011: General requirement of return, statement, or list - § 6011(e), § 6011(f): Pub. L. 97–248 added subsec. (e) and redesignated former subsec. (e) as (f). ## § 6013: Joint returns of income tax by husband and wife - § 6013(g)(1)(B): (h)(1). Pub. L. 97–248 provided that, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983, subsec. (g)(1)(B) is amended by substituting “(relating to withholding on wages, interest, dividends, and patronage dividends)” for “(relating to wage withholding)” and by striking out “of wages”, and subsec. (h)(1) is amended by substituting “(relating to withholding on wages, interest, dividends, and patronage dividends)” for “(relating to wage withholding)” and by striking out “of wages”. Section 102(a), (b) of Pub. L. 98–67, title I, Aug. 5, 1983, 97 Stat. 369, repealed subtitle A (§§ 301–308) of title III of Pub. L. 97–248 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 [now 1986] [this title] shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. ## § 6031: Return of partnership income - § 6031(a): Pub. L. 97–248, § 403(b), designated existing provisions as subsec. (a) and added subsec. heading. - § 6031(b): Pub. L. 97–248, § 403(a), added subsec. (b). ## § 6038: Information reporting with respect to certain foreign corporations and partnerships - § 6038(a)(1): Pub. L. 97–248, § 338(c)(2), substituted “subsection (e)(1)” for “subsection (d)(1)”. - § 6038(b): Pub. L. 97–248, § 338(a), added subsec. (b). Former subsec. (b) redesignated (c). - § 6038(c): Pub. L. 97–248, § 338(a), (b), (c)(1), (3), redesignated former subsec. (b) as (c), substituted “Penalty of reducing foreign tax credit” for “Effect of failure to furnish information” in heading, inserted “of such failure” after “90 days or more after notice” in par. (1), added par. (3), redesignated former par. (3) as (4), and in par. (4) inserted reference to subsection (b) in subpar. (B). Former subsec. (c) redesignated (d). - § 6038(d), § 6038(e): Pub. L. 97–248, § 338(a), redesignated former subsec. (c) as (d). Former subsec. (d), relating to definitions, redesignated (e). ## § 6038A: Information with respect to certain foreign-owned corporations - Enacted 26 U.S.C. § 6038A. ## § 6041: Information at source - § 6041(a): Pub. L. 97–248 substituted “6049(a)” for “6049(a)(1)”, and “or 6045” for “6045, 6049(a)(2), or 6049(a)(3)”. ## § 6041A: Returns regarding payments of remuneration for services and direct sales - Enacted 26 U.S.C. § 6041A. ## § 6042: Returns regarding payments of dividends and corporate earnings and profits - § 6042(a)(1), § 6042(c), § 6042: Pub. L. 97–248 provided that, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983, subsecs. (a)(1) and (c) are amended and a new subsec. (e) is added. Section 102(a), (b) of Pub. L. 98–67, title I, Aug. 5, 1983, 97 Stat. 369, repealed subtitle A (§§ 301–308) of title III of Pub. L. 97–248 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 [now 1986] [this title] shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. ## § 6044: Returns regarding payments of patronage dividends - § 6044(a)(1), § 6044(b)(1), § 6044(e), § 6044: Pub. L. 97–248 provided that, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983, subsecs. (a)(1), (b)(1), and (e) are amended and a new subsec. (f) is added. Section 102(a), (b) of Pub. L. 98–67, title I, Aug. 5, 1983, 97 Stat. 369, repealed subtitle A (§§ 301–308) of Pub. L. 97–248 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 [now 1986] [this title] shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. ## § 6045: Returns of brokers - § 6045: Pub. L. 97–248 designated existing provisions as subsec. (a), substituted “the name and address of each customer, with such details regarding gross proceeds” for “the names of customers for whom such person has transacted any business, with such details regarding the profits and losses” after “may prescribe, showing” and “such business” for “each customer as will enable the Secretary to determine the amount of such profits and losses” after “with respect to”, and added subsecs. (b) and (c). ## § 6046: Returns as to organization or reorganization of foreign corporations and as to acquisitions of their stock - § 6046(d): Pub. L. 97–248 inserted “(or on or before such later day as the Secretary may by forms or regulations prescribe)”. ## § 6046A: Returns as to interests in foreign partnerships - Enacted 26 U.S.C. § 6046A. ## § 6047: Information relating to certain trusts and annuity plans - § 6047(e), § 6047(f): Pub. L. 97–248 added subsec. (e) and redesignated former subsec. (e) as (f). ## § 6048: Information with respect to certain foreign trusts - § 6048(a): Pub. L. 97–248 inserted “(or on or before such later day as the Secretary may by regulations prescribe)” after “the 90th day”. ## § 6049: Returns regarding payments of interest - § 6049(a): Pub. L. 97–248, § 309(a), redesignated subpars. (A) and (B) of former par. (1) as pars. (1) and (2), respectively, in par. (2) as so redesignated inserted “(as so defined)” after “payments of interest”, substituted par. (3) for former par. (1)(C) which described corporations with evidence of outstanding indebtedness in registered form for which during any calendar year there was at least $10 of original issue discount includible in the gross income of a holder under section 1232(a)(3) of this title without regard to subpar. (B) thereof, substituted “of such payments, tax deducted and withheld, and the name and address of the person to whom paid or from whom withheld” for “of such payments and such aggregate amount includible in the gross income of any holder and the name and address of the person to whom paid or such holder” in provisions following par. (3), formerly following par. (1)(C), and struck out former par. (2), which directed persons making aggregate interest payments of less than $10 to another person during any calendar year to report such payments and the recipients when required by the Secretary, and former par. (3), which required all corporations making payments of any amount of interest other than as defined in subsec. (b) to report such payments and the recipients when required by the Secretary. - § 6049(b): Pub. L. 97–248, § 309(a), substituted “subsection (a)” for “subsections (a)(1) and (2)” in provisions preceding subpar. (A), in subpar. (A) substituted “any obligation (i) issued in registered form, or (ii) of a type offered to the public, other than any obligation with a maturity (at issue) of not more than 1 year which is held by a corporation” for “evidences of indebtedness (including bonds, debentures, notes, and certificates) issued by a corporation in registered form, and, to the extent provided in regulations prescribed by the Secretary, interest on other evidences of indebtedness issued by a corporation of a type offered by corporations to the public” in subpar. (C) inserted “industrial loan association or bank” to list of payors of interest, in subpar. (E) substituted “brokers (as defined in section 6045(c))” for “stockbrokers and dealers in securities”, added subpars. (F) and (G), in par. (2) substituted “subsection (a)” for “subsections (a)(1) and (2)” in provisions preceding subpar. (A), added subpar. (A), redesignated former subpar. (A) as (B), in subpar. (B) as so redesignated inserted reference to exemption under any provision of law, added subpar. (C), redesignated former subpar. (B) as (D), in subpar. (D) as so redesignated substituted provisions that the subpar. operates except to the extent otherwise provided in regulations or in subpar. (C) for provisions that the subpar. operates to the extent provided in regulations, added cls. (i) and (ii), designated existing provisions as cls. (iii) to (v), in cl. (iii) as so designated inserted specification of not being engaged in trade or business in the United States, in cl. (iv) as so designated inserted specification of exemption under subchapter A of chapter 3, redesignated former subpar. (C) as (E), and added par. (3). - § 6049(c): Pub. L. 97–248, § 309(a), substituted “subsection (a)” for “subsection (a)(1)” wherever appearing, designated provision before former par. (1) as par. (1), redesignated former pars. (1) and (2) as subpars. (A) and (B), respectively, added subpar. (C), designated first sentence after former par. (2) as par. (2), designated second sentence after former par. (2) as par. (3), in par. (3) as so designated inserted “with respect to payments of interest to any person” after “No statement”, struck out “, or the aggregate amount includible in the gross income of,” after “payments to”, and substituted “paragraph (1) or (2)” for “subparagraph (A), (B), or (C)” after “with respect to”. - § 6049(d): Pub. L. 97–248, § 309(a), added subsec. (d). - § 6049: Pub. L. 97–248, §§ 303(b), 308(a), provided that, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983, a new subsec. (e) is added. Section 102(a), (b) of Pub. L. 98–67, title I, Aug. 5, 1983, 97 Stat. 369, repealed subtitle A (§§ 301–308) of title III of Pub. L. 97–248 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 [now 1986] [this title] shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. ## § 6050E: State and local income tax refunds - Enacted 26 U.S.C. § 6050E. ## § 6051: Receipts for employees - § 6051(f)(1)(A): Pub. L. 97–248 provided that, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983, par. (1)(A) is amended by inserting “subchapter A of” before “chapter 24”. Section 102(a), (b) of Pub. L. 98–67, title I, Aug. 5, 1983, 97 Stat. 369, repealed subtitle A (§§ 301–308) of title III of Pub. L. 97–248 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 [now 1986] [this title] shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. ## § 6053: Reporting of tips - § 6053(c): Pub. L. 97–248 added subsec. (c). ## § 6081: Extension of time for filing returns - § 6081(b): Pub. L. 97–248 struck out “or the first installment thereof required under section 6152” after “the amount properly estimated as its tax”. ## § 6103: Confidentiality and disclosure of returns and return information - § 6103(i)(1), § 6103(i)(2), § 6103(i)(3), § 6103(i)(4), § 6103(i)(5): Pub. L. 97–248, § 356(a), added pars. (1) to (5). Former pars. (1) to (5) were struck out. - § 6103(i)(6): Pub. L. 97–248, § 356(a), added par. (6). Former par. (6) redesignated (7). - § 6103(i)(7): Pub. L. 97–248, §§ 356(a), 358(a), (b), redesignated former par. (6) as (7) and, in par. (7) as so redesignated, substituted “subparagraph (C)” for “subparagraph (B)” in subpar. (A), added subpar. (B), redesignated former subpar. (B) as (C), and in subpar. (C) as so redesignated substituted “subparagraph (A) or (B)” for “subparagraph (A)”. - § 6103(p)(3)(A): Pub. L. 97–248, § 356(b)(1)(A), substituted “(7)(A)(ii)” for “(6)(A)(ii)”. - § 6103(p)(3)(C)(i): Pub. L. 97–248, § 356(b)(1)(B), inserted “, (i)(3)(B)(i),” after “described in subsection (d)”. - § 6103(p)(3)(C)(i)(II): Pub. L. 97–248, § 356(b)(1)(C), inserted “or otherwise” after “such requests”. - § 6103(p)(4): Pub. L. 97–248, § 356(b)(1)(D), (E), substituted “(i)(1), (2), (3), or (5)” for “(i)(1), (2), or (5)” wherever appearing, and inserted “, (i)(3)(B)(i),” after “(d)” wherever appearing. - § 6103(p)(6)(B)(i): Pub. L. 97–248, § 356(b)(1)(F), substituted “subsection (i)(7)(A)(ii)” for “subsection (i)(6)(A)(ii)”. ## § 6157: Payment of Federal unemployment tax on quarterly or other time period basis - § 6157(b): Pub. L. 97–248, § 271(c)(3)(C), substituted “0.6” for “0.5” in two places. - § 6157(b): Pub. L. 97–248, § 271(b)(2)(C), substituted “0.8” for “0.7”. ## § 6164: Extension of time for payment of taxes by corporations expecting carrybacks - § 6164(c): Pub. L. 97–248, § 234(b)(2)(C)(i), substituted “shall be the date on which payment would have been required if such remainder had been the tax” for “shall be considered to be the dates on which payments would have been required if such remainder had been the tax and the taxpayer had elected to pay the tax in installments as provided in section 6152” in last sentence. - § 6164(g)(2): Pub. L. 97–248, § 234(b)(2)(C)(ii), substituted “date on which payment would have been required if there had been no extension with respect to such amount” for “dates on which payments would have been required if there had been no extension with respect to such amount and the taxpayer had elected to pay the tax in installments as provided in section 6152”. ## § 6213: Restrictions applicable to deficiencies; petition to Tax Court - § 6213(h): Pub. L. 97–248 added par. (4). ## § 6216: Cross references - § 6216(4): Pub. L. 97–248 added par. (4). ## § 6325: Release of lien or discharge of property - § 6325(a): Pub. L. 97–248 in introductory provisions substituted “shall issue” for “may issue” and “not later than 30 days after the day on which” for “if”. ## § 6331: Levy and distraint - § 6331(d): Pub. L. 97–248 inserted authority to levy upon property other than salary or wages, substituted “person” for “individual” wherever appearing, designated second sentence of former par. (1) as par. (2) and in par. (2)(C) as so designated substituted “certified or registered mail” for “mail”, and redesignated former par. (2) as (3) and former par. (3) as subsec. (e). - § 6331(e): Pub. L. 97–248 redesignated former subsec. (d)(3) as (e). Former subsec. (e) redesignated (f). - § 6331(f): Pub. L. 97–248 redesignated former subsec. (e) as (f). ## § 6334: Property exempt from levy - § 6334(a)(2): Pub. L. 97–248, § 347(a)(1), substituted “$1,500” for “$500”. - § 6334(a)(3): Pub. L. 97–248, § 347(a)(2), substituted “$1,000” for “$250”. - § 6334(d)(1): Pub. L. 97–248, § 347(a)(3)(A), substituted “$75” for “$50”. - § 6334(d)(1): Pub. L. 97–248, § 347(a)(3)(B), substituted “$25” for “$15”. ## § 6337: Redemption of property - § 6337(b)(1): Pub. L. 97–248 substituted “180 days” for “120 days”. ## § 6401: Amounts treated as overpayments - § 6401(b): Pub. L. 97–248 provided that, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983, subsec. (b) is amended by inserting “, interest, dividends, and patronage dividends” after “tax withheld on wages”. Section 102(a), (b) of Pub. L. 98–67, title I, Aug. 5, 1983, 97 Stat. 369, repealed subtitle A (§§ 301–308) of title III of Pub. L. 97–247 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 [now 1986] [this title] shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. ## § 6413: Special rules applicable to certain employment taxes - § 6413: Catchline and subsecs. (a)(1), (b), (c)(1). Pub. L. 97–248 provided that, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983, the section catchline is amended by substituting “taxes under subtitle C” for “employment taxes”; subsec. (a)(1) is amended by substituting “3402 or 3451 is paid with respect to any payment of remuneration, interest, dividends, or other amounts,” for “or 3402 is paid with respect to any payment of remuneration,”; subsec. (b) is amended by striking out “of certain employment taxes” from heading, and by substituting “3402 or 3451 is paid or deducted with respect to any payment of remuneration, interest, dividends, or other amount”; and subsec. (c)(1) is amended by substituting “section 31(c)” for “section 31(b)”. Section 102(a), (b) of Pub. L. 98–67, title I, Aug. 5, 1983, 97 Stat. 369, repealed sub­title A (§§ 301–308) of title III of Pub. L. 97–248 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 [now 1986] [this title] shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. ## § 6422: Cross references - § 6422: Pub. L. 97–248 added par. (15). ## § 6427: Fuels not used for taxable purposes - § 6427(d): Pub. L. 97–248 inserted “or in certain helicopters” after “museums” in heading and “or is used in a helicopter for a purpose described in section 4041(l),” after “section 4041(h)(2)(C),” in text. ## § 6501: Limitations on assessment and collection - § 6501(o): Pub. L. 97–248 substituted “Special rules for partnership items” for “Special rules for partnership items of federally registered partnerships” in heading and, in text, substituted cross reference to section 6229 for extension of period in case of partnership items (as defined in section 6231(a)(3)), for provisions that (1) in the case of any tax imposed by subtitle A with respect to any person, the period for assessing a deficiency attributable to any partnership item of a federally registered partnership would not expire before the later of (A) the date which was 4 years after the date on which the partnership return of the federally registered partnership for the partnership taxable year in which the item arose was filed (or, later, if the date prescribed for filing the return), or (B) if the name or address of such person did not appear on the partnership return, the date which was 1 year after the date on which such information was furnished to the Secretary in such manner and at such place as he might prescribe by regulations, (2) for purposes of this subsec., the term “partnership item” meant (A) any item required to be taken into account for the partnership taxable year under any provision of subchapter K of chapter 1 to the extent that regulations prescribed by the Secretary provided that for purposes of this subtitle such item was more appropriately determined at the partnership level than at the partner level, and (B) any other item to the extent affected by an item described in subpar. (A), (3) the extensions referred to in subsec. (c)(4), insofar as they related to partnership items, could, with respect to any person, be consented to (A) except to the extent the Secretary was otherwise notified by the partnership, by a general partner of the partnership, or (B) by any person authorized to do so by the partnership in writing, and (4) for purposes of this subsec., the term “federally registered partnership” meant, with respect to any partnership taxable year, any partnership (A) interests in which had been offered for sale at any time during such taxable year or a prior taxable year in any offering required to be registered with the Securities and Exchange Commission, or (B) which, at any time during such taxable year or a prior taxable year, had been subject to the annual reporting requirements of the Securities and Exchange Commission which related to the protection of investors in the partnership. ## § 6504: Cross references - § 6504: Pub. L. 97–248 added par. (12). ## § 6511: Limitations on credit or refund - § 6511(g): Pub. L. 97–248 substituted “Special rule for claims with respect to partnership items” for “Special rule for partnership items of federally registered partnerships” in heading and, in text, substituted provisions that, in the case of any tax imposed by subtitle A with respect to any person which is attributable to any partnership item (as defined in section 6231(a)(3)), the provisions of section 6227 and subsecs. (c) and (d) of section 6230 shall apply in lieu of the provisions of this subchapter for provisions that (1) in the case of any tax imposed by subtitle A with respect to any person, the period for filing a claim for credit or refund of any overpayment attributable to any partnership item of a federally registered partnership would not expire before the later of (A) the date which was 4 years after the date prescribed by law (including extensions thereof) for filing the partnership return for the partnership taxable year in which the item arose, or (B) if an agreement under the provisions of section 6501(c)(4) extending the period for the assessment of any deficiency attributable to such partnership item was made before the date specified in subpar. (A), the date 6 months after the expiration of such extension, with the amount of the credit or refund allowed to exceed the portion of the tax paid within the period provided in subsec. (b)(2) or (c), whichever was applicable, and (2) for purposes of this subsec., the terms “partnership item” and “federally registered partnership” would have the same meanings as such terms had when used in section 6501(o). ## § 6512: Limitations in case of petition to Tax Court - § 6512(a)(4): Pub. L. 97–248, § 402(c)(8), added par. (4). - § 6512(b)(2): Pub. L. 97–248, § 402(c)(9), substituted “(c), or (d)” for “(c), (d), or (g)” wherever appearing. ## § 6515: Cross references - § 6515: Pub. L. 97–248 added par. (7). ## § 6601: Interest on underpayment, nonpayment, or extensions of time for payment, of tax - § 6601(d)(1): Pub. L. 97–248, § 346(c)(2)(A), substituted “the filing date for the taxable year” for “the last day of the taxable year”. - § 6601(d)(2): Pub. L. 97–248, § 346(c)(2)(B), as amended by Pub. L. 98–369, § 346(c)(2)(B), substituted “the filing date for” for “the last day of” in two places. - § 6601(d)(4): Pub. L. 97–248, § 346(c)(2)(C), added par. (4). - § 6601(e): Pub. L. 97–248, § 344(b)(1), struck out par. (2) which had provided that no interest under this section was to be imposed on the interest provided by this section, and redesignated pars. (3) and (4) as (2) and (3), respectively. ## § 6611: Interest on overpayments - § 6611(b)(3): Pub. L. 97–248, § 346(a), added par. (3). - § 6611(f)(1): Pub. L. 97–248, § 346(c)(1)(A), substituted “the filing date for the taxable year” for “the close of the taxable year”. - § 6611(f)(2): Pub. L. 97–248, § 346(c)(1)(B), substituted “the filing date for” for “the close of” wherever appearing. - § 6611(f)(3), § 6611(f)(4): Pub. L. 97–248, § 346(c)(1)(C), added par. (3) and redesignated former par. (3) as (4). - § 6611(g): Pub. L. 97–248, § 346(c)(1)(D), substituted “the filing date (as defined in subsection (f)(3)) for the taxable year” for “the close of the taxable year”. - § 6611: Pub. L. 97–248, § 346(b), added subsec. (i) and redesignated former subsec. (i) as (j). ## § 6621: Determination of rate of interest - § 6621(b): Pub. L. 97–248 substituted provisions that if the adjusted prime rate charged by banks (rounded to the nearest full percent) during the 6-month period ending on September 30 of any calendar year, or during the 6-month period ending on March 31 of any calendar year, differs from the interest rate in effect under this section on either such date, respectively, then the Secretary shall establish, within 15 days after the close of the applicable 6-month period, an adjusted rate of interest equal to such adjusted prime rate, and that any adjusted rate of interest established under paragraph (1) shall become effective on January 1 of the succeeding year in the case of an adjustment attributable to paragraph (1)(A), and on July 1 of the same year in the case of an adjustment attributable to paragraph (1)(B), for provisions that the Secretary was to establish an adjusted rate of interest for the purpose of subsection (a) not later than October 15 of any year if the adjusted prime rate charged by banks during September of that year, rounded to the nearest full percent, was at least a full percentage point more or less than the interest rate which was then in effect, and that any such adjusted rate of interest would be equal to the adjusted prime rate charged by banks, rounded to the nearest full percent, and would become effective on January 1 of the immediately succeeding year. ## § 6622: Interest compounded daily - Enacted 26 U.S.C. § 6622. ## § 6651: Failure to file tax return or to pay tax - § 6651(a): Pub. L. 97–248, § 318(a), inserted provision that, in the case of a failure to file a return of tax imposed by chapter 1 within 60 days of the date prescribed for filing of such return (determined with regard to any extensions of time for filing), unless it is shown that such failure is due to reasonable cause and not due to willful neglect, the addition to tax under par. (1) shall not be less than the lesser of $100 or 100 percent of the amount required to be shown as tax on such return. - § 6651(c)(1): Pub. L. 97–248, § 318(b)(1), inserted provision that in any case described in last sentence of subsec. (a), the amount of the addition under par. (1) of subsec. (a) shall not be reduced under first sentence of this subpar. below the amount provided in such last sentence. - § 6651(c)(1): Pub. L. 97–248, § 318(b)(2), inserted “(determined without regard to the last sentence of such subsection)” after “paragraph (1) of subsection (a)”. ## § 6652: Failure to file certain information returns, registration statements, etc. - § 6652(a): Pub. L. 97–248, § 315(a), designated existing provisions as par. (1) with a heading “In general”, redesignated former par. (1) as subpar. (A), in subpar. (A) as so redesignated struck out “aggregate” before “amount”, redesignated former subpars. (A) through (F) as cls. (i) through (vi), respectively, in cls. (ii) and (iii) as so redesignated struck out “aggregating $10 or more” after “dividends”, in cl. (iv) as so redesignated substituted “(a)” for “(a)(1)” and struck out “aggregating $10 or more” after “interest”, in cl. (vi) as so redesignated inserted “6042(e), 6044(f), 6049(e), or” before “6051(d)”, redesignated former par. (2) as subpar. (B), in subpar. (B) as so redesignated designated from “section 6052(a)” through the end of the parenthesis as cl. (iii) and struck out “with respect to group-term life insurance on the life of an employee” thereafter, added cls. (i), (ii), and (iv), in text after cl. (iv) substituted “subparagraph (A)” for “paragraph (1)”, “subparagraph (B)” for “paragraph (2)”, “$50 for each such failure” for “$10 for each such failure”, and “shall not exceed $50,000” for “shall not exceed $25,000”, and added par. (2). - § 6652(b): Pub. L. 97–248, § 309(b)(2), struck out pars. (3) and (4) which referred to section 6049(a)(2) and section 6049(a)(3), respectively, as sources of authority for the requirement of filing a statement of payment to another person. - § 6652(f): Pub. L. 97–248, § 315(b), substituted “$25” and “$15,000” for “$10” and “$5,000”, respectively. ## § 6653: Failure to pay stamp tax - § 6653: Pub. L. 97–248 designated first sentence of existing provisions as par. (1) with heading “In general”, struck out second sentence which provided that in the case of income taxes and gift taxes, the amount under this subsec. shall be in lieu of any amount determined under subsec. (a), added pars. (2) and (3), designated last sentence as par. (4) with heading “Special rule for joint returns”, and in par. (4) as so designated substituted “of the spouse” for “of a spouse”. ## § 6654: Failure by individual to pay estimated income tax - § 6654(e)(1): Pub. L. 97–248, §§ 307(a)(14), 308(a), provided that, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983, par. (1) is amended by inserting “, interest, dividends, and patronage dividends” after “tax withheld at source on wages”. Section 102(a), (b) of Pub. L. 98–67, title I, Aug. 5, 1983, 97 Stat. 369, repealed subtitle A (§§ 301–308) of title III of Pub. L. 97–248 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 [now 1986] [this title] shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. - § 6654(g): Pub. L. 97–248, § 328(a)(2), substituted “(f), and (h)” for “and (f)”. - § 6654(g)(1): Pub. L. 97–248, § 201(d)(7), formerly § 201(c)(7), substituted “section 55” for “section 55 or 56”. - § 6654(g): Pub. L. 97–248, §§ 307(a)(14), 308(a), provided that, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983, subsec. (g)(3) is amended by inserting “, interest, dividends, and patronage dividends” after “tax withheld at source on wages”. Section 102(a), (b) of Pub. L. 98–67, title I, Aug. 5, 1983, 97 Stat. 369, repealed subtitle A (§§ 301–308) of title III of Pub. L. 97–248 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 [now 1986] [this title] shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. - § 6654(h), § 6654(i): Pub. L. 97–248, § 328(a)(1), added subsec. (h) and redesignated former subsec. (h) as (i). ## § 6655: Failure by corporation to pay estimated income tax - § 6655(a): Pub. L. 97–248, § 234(c), in heading substituted “Addition to tax” for “Addition to the tax”, in provisions preceding par. (1) inserted reference to subsec. (e) as an exception and struck out “estimated” before “tax”, designated existing provisions as par. (1), and in par. (1) as so designated struck out parenthetical reference to subsecs. (b) and (c) for determination of the amount of the underpayment and the period of the underpayment, respectively, and added par. (2). - § 6655(b)(1): Pub. L. 97–248, § 234(a)(1), substituted “90” for “80” wherever appearing. - § 6655(d): Pub. L. 97–248, § 234(a)(2), substituted “90” for “80”. - § 6655(e): Pub. L. 97–248, § 234(d)(1), added subsec. (e). Former subsec. (e) redesignated (f). - § 6655(f): Pub. L. 97–248, § 234(d), redesignated former subsec. (e) as (f) and substituted references to subsecs. (e) and (i) for references to subsec. (h). Former subsec. (f) redesignated (g). - § 6655(g), § 6655(h), § 6655(i): Pub. L. 97–248, § 234(d)(1), redesignated former subsecs. (f) to (h) as (g) to (i), respectively. ## § 6673: Sanctions and costs awarded by courts - § 6673: Pub. L. 97–248, § 292(d)(2)(A), substituted “primarily for delay, etc.” for “merely for delay” after “Tax Court” in section catchline. - § 6673(a): Pub. L. 97–248, § 292(b), substituted “or maintained by the taxpayer primarily for delay or that the taxpayer’s position in such proceedings is frivolous or groundless, damages in an amount not in excess of $5,000” for “by the taxpayer merely for delay, damages in an amount not in excess of $500” in first sentence. ## § 6679: Failure to file returns, etc., with respect to foreign corporations or foreign partnerships - § 6679: Pub. L. 97–248, §§ 340(b)(2), 405(c)(2), as amended by Pub. L. 97–448, § 306(c)(2)(B), substituted “Failure to file returns, etc., with respect to foreign corporations or foreign partnerships” for “Failure to file returns as to organization or reorganization of foreign corporations and as to acquisitions of their stock” in section catchline. - § 6679(a): Pub. L. 97–248, §§ 340(b)(1), 405(b), as amended by Pub. L. 97–448, § 306(a)(2)(A), substituted “section 6035, 6046, or 6046A” for “section 6046”. ## § 6682: False information with respect to withholding - § 6682(a)(1): Pub. L. 97–248 provided that, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983, par. (1) is amended by inserting “or section 3452(f)(1)(A)” after “section 3402”. Section 102(a), (b) of Pub. L. 98–67, title I, Aug. 5, 1983, 97 Stat. 369, repealed subtitle A (§§ 301–308) of title III of Pub. L. 97–248 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 [now 1986] [this title] shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. ## § 6700: Promoting abusive tax shelters, etc. - Enacted 26 U.S.C. § 6700. ## § 6701: Penalties for aiding and abetting understatement of tax liability - Enacted 26 U.S.C. § 6701. ## § 6702: Frivolous tax submissions - Enacted 26 U.S.C. § 6702. ## § 6703: Rules applicable to penalties under sections 6700, 6701, and 6702 - Enacted 26 U.S.C. § 6703. ## § 6704: Failure to keep records necessary to meet reporting requirements under section 6047(d) - Enacted 26 U.S.C. § 6704. ## § 6867: Presumptions where owner of large amount of cash is not identified - Enacted 26 U.S.C. § 6867. ## § 7201: Attempt to evade or defeat tax - § 7201: Pub. L. 97–248 substituted “$100,000 ($500,000 in the case of a corporation)” for “$10,000”. ## § 7203: Willful failure to file return, supply information, or pay tax - § 7203: Pub. L. 97–248, § 329(b), substituted “$25,000 ($100,000 in the case of a corporation)” for “$10,000”. - § 7203: Pub. L. 97–248, § 327, inserted last sentence providing that, in the case of any person with respect to whom there is a failure to pay any estimated tax, this section shall not apply to such person with respect to such failure if there is no addition to tax under section 6654 or 6655 with respect to such failure. ## § 7205: Fraudulent withholding exemption certificate or failure to supply information - § 7205: Pub. L. 97–248 provided that, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983, this section is amended by designating the existing provisions as subsec. (a) with a heading of “Withholding on wages”, and by adding a new subsec. (b). Section 102(a), (b) of Pub. L. 98–67, title I, Aug. 5, 1983, 97 Stat. 369, repealed subtitle A (§§ 301–308) of title III of Pub. L. 97–248 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 [now 1986] [this title] shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. Subsec. (b), referred to above, read as follows: ## § 7206: Fraud and false statements - § 7206: Pub. L. 97–248 substituted “$100,000 ($500,000 in the case of a corporation)” for “$5,000”. ## § 7207: Fraudulent returns, statements, or other documents - § 7207: Pub. L. 97–248 substituted “$10,000 ($50,000 in the case of a corporation)” for “$1,000” wherever appearing. ## § 7213: Unauthorized disclosure of information - § 7213(a)(2): Pub. L. 97–248 inserted “(i)(3)(B)(i),” after “under subsection (d),”. ## § 7215: Offenses with respect to collected taxes - § 7215(b): Pub. L. 97–248 provided that, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983, last sentence of subsec. (b) is amended to read as follows: “For purposes of paragraph (2), a lack of funds existing immediately after the payment of wages or amounts subject to withholding under subchapter B of chapter 24 (whether or not created by the payment of such wages or amounts) shall not be considered to be circumstances beyond the control of a person.” Section 102(a), (b) of Pub. L. 98–67, title I, Aug. 5, 1983, 97 Stat. 369, repealed subtitle A (§§ 301–308) of title III of Pub. L. 97–248 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 [now 1986] [this title] shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. ## § 7275: Penalty for offenses relating to certain airline tickets and advertising - § 7275(a): Pub. L. 97–248 redesignated former par. (1) as pars. (1) and (2) and struck out former par. (2) which provided that a ticket for transportation, if it showed amounts paid with respect to any segment of such transportation, had to comply with former par. (1) with respect to such segments as well as with respect to the sum of the segments. ## § 7408: Actions to enjoin specified conduct related to tax shelters and reportable transactions - Enacted 26 U.S.C. § 7408. ## § 7410: Cross references ## § 7422: Civil actions for refund - § 7422(h), § 7422(i): Pub. L. 97–248 added subsec. (h) and redesignated former subsec. (h) as (i). ## § 7426: Civil actions by persons other than taxpayers - § 7426(b)(2)(C): Pub. L. 97–248 inserted “if such property was sold,” before “grant a judgment” and “the greater of—” after “not exceeding”, redesignated remaining provisions as cl. (i), and added cl. (ii). ## § 7430: Awarding of costs and certain fees - Enacted 26 U.S.C. § 7430. ## § 7431: Civil damages for unauthorized inspection or disclosure of returns and return information - Enacted 26 U.S.C. § 7431. ## § 7437: Cross references ## § 7451: Petitions - § 7451: Pub. L. 97–248 inserted provision relating to judicial review under section 6226 or section 6228(a). ## § 7456: Administration of oaths and procurement of testimony - § 7456(c): Pub. L. 97–248 inserted “6226, 6228(a),” after “proceedings under sections”. ## § 7459: Reports and decisions - § 7459(c): Pub. L. 97–248 inserted “or in the case of an action brought under section 6226 or section 6228(a)” after “or under section 7428”. ## § 7482: Courts of review - § 7482(b)(1): Pub. L. 97–248 added subpar. (F), and in provisions following subpar. (F) inserted “, or the petition under section 6226 or 6228(a),” after “or 7477”. ## § 7485: Bond to stay assessment and collection - § 7485(b), § 7485(c): Pub. L. 97–248 added subsec. (b) and redesignated former subsec. (b) as (c). ## § 7602: Examination of books and witnesses - § 7602: Pub. L. 97–248 redesignated existing provisions as subsec. (a), added subsec. (a) heading, and added subsecs. (b) and (c). ## § 7609: Special procedures for third-party summonses - § 7609(a)(1): Pub. L. 97–248, § 331(d)(1), substituted “the 23rd day” for “the 14th day”, and substituted “an explanation of the right under subsection (b)(2) to bring a proceeding to quash the summons” for “directions for staying compliance with the summons under subsection (b)(2)” at the end. - § 7609(a)(3): Pub. L. 97–248, § 311(b), added subpar. (G). - § 7609(b): Pub. L. 97–248, § 331(a), (d)(2), substituted “right to proceeding to quash” for “right to stay compliance” in heading, and in par. (2) substituted “Proceeding to quash” for “Right to stay compliance” as par. (2) heading, designated former undesignated matter as subpar. (A), in (A) as so designated substituted provisions giving persons entitled to notice 20 days to begin a proceeding to quash, for provisions giving persons entitled to notice the right to stay compliance if they complied with the provisions of former subpars. (A) and (B) within 14 days, and inserted provision that the Secretary may seek to compel compliance with the summons, struck out former subpar. (A) which provided that notice to the person summoned not to comply with the summons be given in writing, in subpar. (B) substituted provisions that copies of the petition in the proceeding to quash the summons be mailed within the 20-day period, for provisions that copies of the notice not to comply with the summons be mailed, and added subpar. (C). - § 7609(d): Pub. L. 97–248, § 331(b), substituted in par. (1) provision that, no examination of records be made before the close of the 23rd day after the notice of summons, for provision that the examination may not be made before the end of the former 14-day period allowed for notice to be given to the person summoned not to comply, and in par. (2) substituted “where a proceeding under subsection (b)(2)(A) was begun within the 20-day period referred to in such subsection and the requirements of subsection (b)(2)(B) have been met,” for “when the requirements of subsection (b)(2) have been met,” and “of the court having jurisdiction of such proceeding or with the consent of the person beginning the proceeding to quash” for “issued by a court of competent jurisdiction authorizing examination of such records or with the consent of the person staying compliance”. - § 7609(h): Pub. L. 97–248, § 331(c), inserted “; etc.” after “court” in heading, in par. (1) added heading and substituted “any proceeding” for “proceedings” after “determine”, substituted “subsection (b)(2), (f), or (g)” for “subsections (f) or (g)”, designated former second sentence of par. (1) as par. (2) and added heading, redesignated former par. (2) as (3) and in par. (3) as so redesignated, added heading and substituted “all other cases” for “all cases”. - § 7609(i): Pub. L. 97–248, § 332(a), added subsec. (i). ## § 7654: Coordination of United States and certain possession individual income taxes - § 7654(d): Pub. L. 97–248 provided that, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983, subsec. (d) is amended by inserting “subchapter A of” before “chapter 24”. Section 102(a), (b) of Pub. L. 98–67, title I, Aug. 5, 1983, 97 Stat. 369, repealed sub­title A (§§ 301–308) of title III of Pub. L. 97–248 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 [now 1986] [this title] shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. ## § 7701: Definitions - § 7701(a)(16): Pub. L. 97–248, §§ 307(a)(17), 308(a), provided that, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983, par. (16) is amended by substituting “1461 or 3451” for “or 1461”. Section 102(a), (b) of Pub. L. 98–67, title I, Aug. 5, 1983, 97 Stat. 369, repealed subtitle A (§§ 301–308) of title III of Pub. L. 97–248 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 [now 1986] [this title] shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. - § 7701(a)(38): Pub. L. 97–248, § 201(d)(10), formerly § 201(c)(10), added par. (38) relating to joint return. - § 7701(a)(38): Pub. L. 97–248, § 336(a), added par. (38) relating to persons residing outside the United States. ## § 9501: Black Lung Disability Trust Fund - § 9501: Pub. L. 97–248 struck out “Establishment of” before “Black Lung” in section catchline. ## § 9502: Airport and Airway Trust Fund - Enacted 26 U.S.C. § 9502.