65 STAT.]
PUBLIC LAW 183—OCT. 20, 1951
505
received from the sale or exchange of a capital asset held for more than six months, if such rights were included in the terms of the employment of such employee for not less than twelve years, and if the total of the amounts received for such assignment or release are received in one taxable year and after the termination of such employment." (b) EFFECTIVE DATE.—The amendment made by this section shall be applicable with respect to taxable years beginning after December 31, 1950. SEC. 330. NET OPERATING LOSS CARRY-OVER. (a) Loss FOR TAXABLE YEAR BEGINNING BEFORE 1948.—So much of subparagraph (A) of section 122(b)(2) (relating to the amount 26u.^s.c!§ 122(b) of carry-overs) as precedes "the taxpayer*' is hereby amended to read (2). as follows: " (A) Loss for Taxable Year Beginning Before 1948.— Except as provided in subparagraph (D), if for any taxable ^"^'•'• year beginning before January 1, 1948,". (b) ALLOWANCE OF THREE-YEAR Loss CARRY-OVER FROM TAXABMJ YEARS 1948-1949.—Section 122(b)(2) (relating to the amount of carry-over) is hereby amended by adding after subparagraph (B) the following new subparagraphs: "(C) Loss for Taxable Year Beginning After December 31, 1947, and Before January 1, 1950.—If for any taxable year beginning after December 31, 1947, and before January 1, 1950, the taxpayer has a net operating loss, such net operating loss shall be a net operating loss carry-over for each of the three succeeding taxable years, except that the carry-over in the case of each such succeeding taxable year (other than the first succeeding taxable year) shall be the excess, if any, of the amount of such net operating loss over the sum of the net income for each of the intervening years computed— "(i) with the exceptions, additions, and limitations provided in subsection (d)(1), (2), (4), and (6), and ^^53stat.867; 56stat. " (ii) by determining the net operating loss deduction 26 U.S.C. § 122 (d). for each intervening taxable year without regard to such net operating loss or to the net operating loss for any succeeding taxable year and without regard to any reduction specified in subsection (c). For the purpose of the preceding sentence, the net operating loss for any taxable year beginning after December 31, 1947, and before January 1, 1950, shall be reduced by the sum of the net income for each of the two preceding taxable years computed— "(iii) with the exceptions, additions, and limitations provided in subsection (d)(1), (2), (4), and (6), and " (iv) by determining the net operating loss deduction without regard to such net operating loss or to the net operating loss for the succeeding taxable year, and without regard to any reduction specified in subsection (c). " (D) Loss for Taxable Year Beginning After December 31, 1946, and Before January 1, 1948, in the Case of a Corporation Which Commenced Business After December 31, 1945.—If for any taxable year beginning after December 31, 1946, and before January 1, 1948, a corporation which commenced business after December 31, 1945, has a net operating loss, such net operating loss shall be a net operating loss carry-over for each of the three succeeding taxable years, except that the carry-over in the case of each such succeeding taxable year (other than the first succeeding taxable year)
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