98 STAT. 614
PUBLIC LAW 98-369—JULY 18, 1984 (and the lessee shall be treated as having paid or incurred) rents equal to the greater of— (i) the amount of rents actually paid under the agreement during the taxable year, or (ii) the amount of rents determined in accordance with the schedule under subparagraph (B) for such taxable year,
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(B) SCHEDULE.—
(i) IN GENERAL.—The schedule under this subparagraph is as follows: >
Portion of lease term: 1st Vs 2nd % 3rd 1/5
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Cumulative percentage of total rent deemed paid: 10 25 45
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Last V k 100. (ii) OPERATING RULES.—For purposes of this sched-
ule— (I) the rent allocable to each taxable year within any portion of a lease term described in such schedule shall be a level pro rata amount properly allocable to such taxable year, and (II) any agreement relating to property which is to be placed in service in 2 or more stages shall be treated as 2 or more separate agreements. (C) PARAGRAPH NOT TO APPLY.—This paragraph shall not apply to any agreement if the sum of the present values of all payments under the agreement is greater than the sum of the present value of all the payments deemed to be paid or received under the schedule under subparagraph (B). For purposes of computing any present value under this subparagraph, the annual discount rate shall be equal to 12 percent, compounded semiannually. SEC. 93. AMORTIZATION OF CONSTRUCTION PERIOD INTEREST AND TAXES FOR RESIDENTIAL REAL PROPERTY HELD BY CORPORATIONS. 26 USC 189. (a) IN GENERAL.—Subsection (d) of section 189 (relating to amortization of real property construction period interest and taxes) is amended— (1) by striking out paragraph (2), and (2) by redesignating paragraph (3) as paragraph (2). 26 USC 189 note. (b) EFFECTIVE DATE.—The amendments made by this section shall apply to taxable years beginning after December 31, 1984, with respect to construction beginning after March 15, 1984. 26 USC 195.
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SEC. 94. CAPITALIZATION OF START-UP EXPENDITURES. (a) IN GENERAL.—Section 195 (relating to start-up expenditures) is amended to read as follows: "SEC. 195. START-UP EXPENDITURES. "(a) CAPITAUZATION OF EXPENDITURES.—Except as otherwise provided in this section, no deduction shall be allowed for start-up expenditures. "(b) ELECTION TO AMORTIZE.—
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