PUBLIC LAW 97-354—OCT. 19, 1982
96 STAT. 1689
(B) by striking out "PARTNERS" in the subparagraph heading and inserting in lieu thereof "PARTNERS AND SHAREHOLDERS OF S CORPORATIONS".
(3) The paragraph heading for paragraph (4) of section 58(i) is amended by striking out "INTEREST AS LIMITED PARTNER" and inserting in lieu thereof "LIMITED BUSINESS INTEREST".
Ante, p. 417.
(d) USED PROPERTY FOR PURPOSES OF INVESTMENT CREDIT (SECTION
48(c)).—Subparagraph (D) of section 48(c)(2) (relating to partnerships) is amended— (1) by adding at the end thereof the following new sentence: "A similar rule shall apply in the case of an S corporation and its shareholders.", and (2) by striking out "PARTNERSHIPS" in the subparagraph heading and inserting in lieu thereof "PARTNERSHIPS AND S
26 USC 48.
CORPORATIONS". (e) INCOME FROM DISCHARGE OF INDEBTEDNESS (SECTION
108).— Paragraph (6) of section 108(d) (relating to application of section at partner level) is amended to read as follows:
26 USC 108.
"(6) SUBSECTIONS (a), (b), AND (C) TO BE APPLIED AT PARTNER LEVEL OR S CORPORATION SHAREHOLDER LEVEL.—In the case of a
partnership, subsections (a), (b), and (c) shall be applied at the partner level. In the case of an S corporation, subsections (a), (b), and (c) shall be applied at the shareholder level." (f) ELECTION TO EXPENSE CERTAIN DEPRECIABLE BUSINESS ASSETS (SECTION 179).—Paragraph (8) of section 179(d) (relating to dollar
limitation in the case of partnerships) is amended— (1) by adding at the end thereof the following new sentence: "A similar rule shall apply in the case of an S corporation and its shareholders.", and (2) by striking out "PARTNERSHIPS" in the paragraph heading and inserting in lieu thereof "PARTNERSHIPS AND S
95 Stat. 219. ^" ^^^ ^' ^•
CORPORATIONS". (g) AMORTIZATION OF REFORESTATION EXPENDITURES (SECTION
194).—Subparagraph (B) of section 194(b)(2) (relating to partnerships) is amended— (1) by adding at the end thereof the following new sentence: "A similar rule shall apply in the case of an S corporation and its shareholders.", and (2) by striking out "PARTNERSHIPS" in the subparagraph heading and inserting in lieu thereof "PARTNERSHIPS AND S
26 USC 194.
CORPORATIONS". (h) TREATMENT OF LOSSES AND UNPAID EXPENSES AND INTEREST IN THE CASE OF TRANSACTIONS BETWEEN S CORPORATIONS AND CERTAIN RELATED ENTITIES (SECTION 267(b)).—
(1) Subsection (b) of section 267 (relating to losses, expenses, and interest with respect to transactions between related taxpayers) is amended by adding at the end thereof the following new paragraphs: "(10) An S corporation and a partnership if the same persons own— "(A) more than 50 percent in value of the outstanding stock of the S corporation, and "(B) more than 50 percent of the capital interest, or the profits interest, in the partnership; "(11) An S corporation and another S corporation if the same persons own more than 50 percent in value of the outstanding stock of each corporation; or
26 USC 267.
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