502
PUBLIC LAW 183—OCT. 20, 1951
[65 STAT.
26 u^*8^^6!^§ 102, tion 102 or subchapter A of chapter 2 (including the computation smetseg.' ' under section 117(c)(1) of a tax in lieu of the tax imposed by ^"'"•P-*^"section 500)." 26 u.^s! a § 117 (k). (c) CLERICAL AMENDMENT.—The heading to section 117(k) (relatAnte, p. 501. ing to the gain or loss upon the cutting of timber) is hereby amended to read as follows: " (k) G A I N OR Loss I N THE CASE OF TIMBER OR COAL.—".
26U*s.c!§48i(a) (^) TECHNICAL AMENDMENT.—Section 481(a) f4) is hereby (4). amended by striking out "cutting or disposal of timber" and inserting in lieu thereof "cutting of timber, or the disposal of timber or coal,. (e)
CONFORMING AMENDMENTS.—
26U.*s. c^*§433.
(1) Section 433 (relating to computation of excess profits net income) is hereby amended by inserting at the end thereof the following new subsection: " (d) G A I N OR Loss U P O N CERTAIN DISPOSALS OF COAL I N BASE PERIOD.—For the purpose of subsection (b), the excess profits net income shall be computed as if the provisions of section 117(j) and Ante, pp. 500,501. (]j)(2) which relate to disposals of coal were a part of the law applicable to the taxable year for which excess profits net income is computed." 64 Stat, mh^^^ ^ ^ ^ (2) Section 440(a)(1) (relating to definition of "inadmissible (1). * assets") is hereby amended by striking out "and" at the end of subparagraph (A); by striking out the period at the end of subparagraph (B) and inserting in lieu thereof "; and "; and by adding at the end thereof the following new subparagraph: " (C) The economic interest referred to in the provisions ^n(e, p.601. of section 117(k)(2) relating to coal if the taxpayer is subject to such provisions with respect to the income from such coal." (3) The amendments made by this subsection shall be appli26 u^s.^c.'^i 430 et cable in computing the tax under subchapter D of chapter 1 for seg. taxable years ending after December 31, 1950. (f) EFFECTIVE DATE.—Except as provided in subsection (e), the amendments made b ^ this section shall be applicable only with respect to taxable years ending after December 31, 1950 (whether the contract was made on, before, or after such date), but shall apply only with respect to amounts received or accrued after such date. SEC 326. COLLAPSIBLE CORPORATIONS. (a) Definitions with Eespect to Collapsible Corporations.—Section 26U^scVi7(m) 117 (m)(2) (relating to definitions with respect to collapsible corpo(2). rations) is hereby amended to read as follows: "(2) DEFINmONS.— " (A) For the purposes of this subsection, the term 'collapsible corporation' means a corporation formed or availed of principally for the manufacture, construction, or production of property, for the purchase of property which (in the ,. hands of the corporation) is property described in subsec26u.*s.^a§ 117(a) tion (a)(1)(A), or for the holding of stock in a corporaCD (A)'. tion so formed or availed of, with a view to— " (i) the sale or exchange of stock by its shareholders (whether in liquidation or otherwise), or a distribution to its shareholders, prior to the realization by the corporation manufacturing, constructing, producing, or purchasing the property of a substantial part of the net income to be derived from such property, and "(ii) the realization by such shareholders of gain attributable to such property.
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