56 STAT.] 77TH CONG. , 2 D SESS.-CH. 619-OCT. 21, 1942 months after the beginning of such construction, recon- struction, erection, or installation or the date of such acqui- sition, or before the expiration of six months after the date of the enactment of the Revenue Act of 1942, whichever is later. In no event and notwithstanding any of the other provisions of this section, no amortization deduction shall be allowed in respect of any emergency facility for any taxable year- "(C) unless a certificate in respect thereof under para- graph (1) shall have been made (i) prior to the filing of the taxpayer's return for such taxable year, or prior to the making of an election pursuant to subsection (d) (3) or subsection (d) (6) of this section to take the amortization deduction, or (ii) before December 1, 1941, whichever is later; or "(D) in the case of an emergency facility completed or acquired by a corporation after December 31, 1939, and before June 11, 1940, unless a certificate in respect thereof under paragraph (1) shall have been made prior to the expiration of twelve months after the date of enactment of the Revenue Act of 1942; or "(E) in the case of an emergency facility completed or acquired after December 31, 1939, and before January 1, 1943, by a person other than a corporation, unless a cer- tificate in respect thereof under paragraph (1) shall have been made (i) prior to the expiration of nine months after the last date upon which an application for such certificate may be filed, or (ii) prior to the expiration of twelve months after the date of enactment of the Revenue Act of 1942, whichever is later." (f) LIE TENANT AND RE1AINDERMAN. -Section 124 is amended by inserting at the end thereof the following new subsection: "(i) LIFE TENANT AND REMAINDERMAN.- In the case of property held by one person for life with remainder to another person, the deduction shall be computed as if the life tenant were the absolute owner of the property and shall be allowable to the life tenant." (g) ALLOWANCE TO ESTATE OR TRnsT. -Supplement E (relating to estates and trusts) of Chapter 1 is amended by inserting at the end thereof the following new section: "SEC. 172. ALLOWANCE OF AMORTIZATION DEDUCTION. "The benefit of the deduction for amortization of emergency facili- ties allowed by section 23 (t) shall be allowed to estates and trusts in the same manner and to the same extent as in the case of an indi- vidual. The allowable deduction shall be apportioned between the income beneficiaries and the fiduciary under regulations prescribed by the Commissioner with the approval of the Secretary. (h) PARTNERSHnIP. -Supplement F (relating to partnerships) of Chapter 1 is amended by inserting at the end thereof the following new section: "SEC. 190. ALLOWANCE OF AMORTIZATION DEDUCTION. "In the case of emergency facilities of a partnership, the benefit of the deduction for amortization allowed by section 23 (t) shall not be allowed to the members of a partnership but shall be allowed to the partnership in the same manner and to the same extent as in the case of an individual." 851 Restriction. Ante, p. 849. 54 Stat. 999. 26U.S. . 1i; Supp. I, 124 . Ante, p. 60. Ant, p. 817. M4Stt. M8. 8U. S. C. 23(t). 53 Stat. 9. 28 .. .C.Ii181- 189. 4 Stat. 998. 26U. .C. 123(t).
�
