102 STAT. 3442
PUBLIC LAW 100-647—NOV. 10, 1988 (2) So much of paragraph (2) of section 453C(d) of the 1986 Code as precedes subparagraph (A) is amended to read as follows: "(2)
26 USC 453C note.
EXCESS ALLOCABLE INSTALLMENT INDEBTEDNESS.—If
the
allocable installment indebtedness for any taxable year exceeds the amount which may be allocated under paragraph (1) to applicable installment obligations arising in (and outstanding as of the close of) such taxable year, such excess shall—". (3) Subparagraph (A) of section 453aeXl) of the 1986 Code is amended by adding at the end thereof the following new sentence: "Such term also includes any obligation held by any person if the basis of such obligation in the hands of such person is determined (in whole or in part) by reference to the basis of such obligation in the hands of another person and such obligation was an applicable installment obligation in the hands of such other person." (4) Paragraph (2) of section 453C(e) of the 1986 Code (relating to aggregation rules) is amended by striking out "For" and inserting in lieu thereof "Except as provided in regulations, for". (5) Subparagraph (B) of section 453C(e)(4) of the 1986 Code is amended by striking out "or (3)". (6) Paragraph (4) of section 811(c) of the Reform Act is amended by striking out the second subparagraphs (D) and (E). (7) Paragraph (5) of section 811(c) of the Reform Act is amended by striking out "October 23, 1985" each place it appears and inserting in lieu thereof "October 23, 1984". (8) Section 811(c) of the Reform Act is amended by adding at the end thereof the following new paragraph: "(9) SPECIAL RULES.—For purposes of section 453C of the 1986 Code (as added by subsection (a))— "(A) REVOLVING CREDIT PLANS, ETC.—The term 'applicable installment obligation' shall not include any obligation arising out of any disposition or sale described in paragraph (1) or (2) of section 453(k) of such Code (as added by section 812(a)). "(B) CERTAIN DISPOSITIONS DEEMED MADE ON FIRST DAY OP TAXABLE YEAR.—In the case of a taxpayer's 1st taxable year
26 USC 453C
- ^ote.
ending after December 31, 1986, dispositions after February 28, 1986, and before the 1st day of such taxable year shall be treated as made on such 1st day." (9) For purposes of applying the amendments made by this subsection and the amendments made by section 10202 of the Revenue Act of 1987, the provisions of this subsection shall be treated as having been enacted immediately before the enactment of the Revenue Act of 1987. (g) AMENDMENTS RELATED TO SECTION 812 OF THE REFORM ACT.—
(1) Section 453 of the 1986 Code is amended by redesignating the subsection (j) added by section 812 of the Reform Act as subsection (k). (2) Subsection (c) of section 453A of the 1986 Code (as in effect on the date before the date of the enactment of the Revenue Act of 1987) is amended by striking out "453(j)" and inserting in lieu thereof "453(k)".
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