26 USC sec. 475

Page 1459

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cedures provided by regulations under section 472.
(B) Year of change
For purposes of this paragraph, the year of
change under this section is—
(i) the 1st taxable year to which an election under this section applies, or
(ii) in the case of a cessation of such an
election, the 1st taxable year after such
election ceases to apply.
(Added Pub. L. 97–34, title II, § 237(a), Aug. 13,
1981, 95 Stat. 252; amended Pub. L. 99–514, title
VIII, § 802(a), Oct. 22, 1986, 100 Stat. 2348.)
AMENDMENTS
1986—Pub. L. 99–514 amended section generally, substituting provisions relating to election by eligible
small business to use simplified dollar-value method of
pricing inventories for purposes of LIFO method for
provisions relating to election by eligible small business which uses dollar-value method of pricing inventories under method provided by section 472(b) of this
title to use one inventory pool for any trade or business
of such eligible small business.
EFFECTIVE DATE OF 1986 AMENDMENT
Pub. L. 99–514, title VIII, § 802(c), Oct. 22, 1986, 100
Stat. 2350, provided that:
‘‘(1) IN GENERAL.—The amendments made by this section [amending this section] shall apply to taxable
years beginning after December 31, 1986.
‘‘(2) TREATMENT OF TAXPAYERS WHO MADE ELECTIONS
UNDER EXISTING SECTION 474.—The amendments made by
this section shall not apply to any taxpayer who made
an election under section 474 of the Internal Revenue
Code of 1954 (as in effect on the day before the date of
the enactment of this Act [Oct. 22, 1986]) for any period
during which such election is in effect. Notwithstanding any provision of such section 474 (as so in effect),
an election under such section may be revoked without
the consent of the Secretary.’’
EFFECTIVE DATE
Pub. L. 97–34, title II, § 237(c), Aug. 13, 1981, 95 Stat.
253, provided that: ‘‘The amendments made by this section [enacting this section] shall apply to taxable years
beginning after December 31, 1981.’’

§ 475. Mark to market accounting method for
dealers in securities
(a) General rule
Notwithstanding any other provision of this
subpart, the following rules shall apply to securities held by a dealer in securities:
(1) Any security which is inventory in the
hands of the dealer shall be included in inventory at its fair market value.
(2) In the case of any security which is not
inventory in the hands of the dealer and which
is held at the close of any taxable year—
(A) the dealer shall recognize gain or loss
as if such security were sold for its fair market value on the last business day of such
taxable year, and
(B) any gain or loss shall be taken into account for such taxable year.
Proper adjustment shall be made in the
amount of any gain or loss subsequently realized for gain or loss taken into account under
the preceding sentence. The Secretary may
provide by regulations for the application of
this paragraph at times other than the times
provided in this paragraph.

§ 475

(b) Exceptions
(1) In general
Subsection (a) shall not apply to—
(A) any security held for investment,
(B)(i) any security described in subsection
(c)(2)(C) which is acquired (including originated) by the taxpayer in the ordinary
course of a trade or business of the taxpayer
and which is not held for sale, and (ii) any
obligation to acquire a security described in
clause (i) if such obligation is entered into in
the ordinary course of such trade or business
and is not held for sale, and
(C) any security which is a hedge with respect to—
(i) a security to which subsection (a)
does not apply, or
(ii) a position, right to income, or a liability which is not a security in the hands
of the taxpayer.
To the extent provided in regulations, subparagraph (C) shall not apply to any security
held by a person in its capacity as a dealer in
securities.
(2) Identification required
A security shall not be treated as described
in subparagraph (A), (B), or (C) of paragraph
(1), as the case may be, unless such security is
clearly identified in the dealer’s records as
being described in such subparagraph before
the close of the day on which it was acquired,
originated, or entered into (or such other time
as the Secretary may by regulations prescribe).
(3) Securities subsequently not exempt
If a security ceases to be described in paragraph (1) at any time after it was identified as
such under paragraph (2), subsection (a) shall
apply to any changes in value of the security
occurring after the cessation.
(4) Special rule for property held for investment
To the extent provided in regulations, subparagraph (A) of paragraph (1) shall not apply
to any security described in subparagraph (D)
or (E) of subsection (c)(2) which is held by a
dealer in such securities.
(c) Definitions
For purposes of this section—
(1) Dealer in securities defined
The term ‘‘dealer in securities’’ means a taxpayer who—
(A) regularly purchases securities from or
sells securities to customers in the ordinary
course of a trade or business; or
(B) regularly offers to enter into, assume,
offset, assign or otherwise terminate positions in securities with customers in the ordinary course of a trade or business.
(2) Security defined
The term ‘‘security’’ means any—
(A) share of stock in a corporation;
(B) partnership or beneficial ownership interest in a widely held or publicly traded
partnership or trust;
(C) note, bond, debenture, or other evidence of indebtedness;

§ 475

TITLE 26—INTERNAL REVENUE CODE

(D) interest rate, currency, or equity notional principal contract;
(E) evidence of an interest in, or a derivative financial instrument in, any security
described in subparagraph (A), (B), (C), or
(D), or any currency, including any option,
forward contract, short position, and any
similar financial instrument in such a security or currency; and
(F) position which—
(i) is not a security described in subparagraph (A), (B), (C), (D), or (E),
(ii) is a hedge with respect to such a security, and
(iii) is clearly identified in the dealer’s
records as being described in this subparagraph before the close of the day on which
it was acquired or entered into (or such
other time as the Secretary may by regulations prescribe).
Subparagraph (E) shall not include any contract to which section 1256(a) applies.
(3) Hedge
The term ‘‘hedge’’ means any position which
manages the dealer’s risk of interest rate or
price changes or currency fluctuations, including any position which is reasonably expected
to become a hedge within 60 days after the acquisition of the position.
(4) Special rules for certain receivables
(A) In general
Paragraph (2)(C) shall not include any nonfinancial customer paper.
(B) Nonfinancial customer paper
For purposes of subparagraph (A), the term
‘‘nonfinancial customer paper’’ means any
receivable which—
(i) is a note, bond, debenture, or other
evidence of indebtedness;
(ii) arises out of the sale of nonfinancial
goods or services by a person the principal
activity of which is the selling or providing of nonfinancial goods or services; and
(iii) is held by such person (or a person
who bears a relationship to such person described in section 267(b) or 707(b)) at all
times since issue.
(d) Special rules
For purposes of this section—
(1) Coordination with certain rules
The rules of sections 263(g), 263A, and 1256(a)
shall not apply to securities to which subsection (a) applies, and section 1091 shall not
apply (and section 1092 shall apply) to any loss
recognized under subsection (a).
(2) Improper identification
If a taxpayer—
(A) identifies any security under subsection (b)(2) as being described in subsection (b)(1) and such security is not so described, or
(B) fails under subsection (c)(2)(F)(iii) to
identify any position which is described in
subsection (c)(2)(F) (without regard to clause
(iii) thereof) at the time such identification
is required,

Page 1460

the provisions of subsection (a) shall apply to
such security or position, except that any loss
under this section prior to the disposition of
the security or position shall be recognized
only to the extent of gain previously recognized under this section (and not previously
taken into account under this paragraph) with
respect to such security or position.
(3) Character of gain or loss
(A) In general
Except as provided in subparagraph (B) or
section 1236(b)—
(i) In general
Any gain or loss with respect to a security under subsection (a)(2) shall be treated as ordinary income or loss.
(ii) Special rule for dispositions
If—
(I) gain or loss is recognized with respect to a security before the close of the
taxable year, and
(II) subsection (a)(2) would have applied if the security were held as of the
close of the taxable year,
such gain or loss shall be treated as ordinary income or loss.
(B) Exception
Subparagraph (A) shall not apply to any
gain or loss which is allocable to a period
during which—
(i) the security is described in subsection
(b)(1)(C) (without regard to subsection
(b)(2)),
(ii) the security is held by a person other
than in connection with its activities as a
dealer in securities, or
(iii) the security is improperly identified
(within the meaning of subparagraph (A)
or (B) of paragraph (2)).
(e) Election of mark to market for dealers in
commodities
(1) In general
In the case of a dealer in commodities who
elects the application of this subsection, this
section shall apply to commodities held by
such dealer in the same manner as this section
applies to securities held by a dealer in securities.
(2) Commodity
For purposes of this subsection and subsection (f), the term ‘‘commodity’’ means—
(A) any commodity which is actively traded (within the meaning of section 1092(d)(1));
(B) any notional principal contract with
respect to any commodity described in subparagraph (A);
(C) any evidence of an interest in, or a derivative instrument in, any commodity described in subparagraph (A) or (B), including
any option, forward contract, futures contract, short position, and any similar instrument in such a commodity; and
(D) any position which—
(i) is not a commodity described in subparagraph (A), (B), or (C),
(ii) is a hedge with respect to such a
commodity, and

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(iii) is clearly identified in the taxpayer’s records as being described in this
subparagraph before the close of the day
on which it was acquired or entered into
(or such other time as the Secretary may
by regulations prescribe).
(3) Election
An election under this subsection may be
made without the consent of the Secretary.
Such an election, once made, shall apply to
the taxable year for which made and all subsequent taxable years unless revoked with the
consent of the Secretary.
(f) Election of mark to market for traders in securities or commodities
(1) Traders in securities
(A) In general
In the case of a person who is engaged in
a trade or business as a trader in securities
and who elects to have this paragraph apply
to such trade or business—
(i) such person shall recognize gain or
loss on any security held in connection
with such trade or business at the close of
any taxable year as if such security were
sold for its fair market value on the last
business day of such taxable year, and
(ii) any gain or loss shall be taken into
account for such taxable year.
Proper adjustment shall be made in the
amount of any gain or loss subsequently realized for gain or loss taken into account
under the preceding sentence. The Secretary
may provide by regulations for the application of this subparagraph at times other
than the times provided in this subparagraph.
(B) Exception
Subparagraph (A) shall not apply to any
security—
(i) which is established to the satisfaction of the Secretary as having no connection to the activities of such person as a
trader, and
(ii) which is clearly identified in such
person’s records as being described in
clause (i) before the close of the day on
which it was acquired, originated, or entered into (or such other time as the Secretary may by regulations prescribe).
If a security ceases to be described in clause
(i) at any time after it was identified as such
under clause (ii), subparagraph (A) shall
apply to any changes in value of the security
occurring after the cessation.
(C) Coordination with section 1259
Any security to which subparagraph (A)
applies and which was acquired in the normal course of the taxpayer’s activities as a
trader in securities shall not be taken into
account in applying section 1259 to any position to which subparagraph (A) does not
apply.
(D) Other rules to apply
Rules similar to the rules of subsections
(b)(4) and (d) shall apply to securities held

§ 475

by a person in any trade or business with respect to which an election under this paragraph is in effect. Subsection (d)(3) shall not
apply under the preceding sentence for purposes of applying sections 1402 and 7704.
(2) Traders in commodities
In the case of a person who is engaged in a
trade or business as a trader in commodities
and who elects to have this paragraph apply to
such trade or business, paragraph (1) shall
apply to commodities held by such trader in
connection with such trade or business in the
same manner as paragraph (1) applies to securities held by a trader in securities.
(3) Election
The elections under paragraphs (1) and (2)
may be made separately for each trade or business and without the consent of the Secretary.
Such an election, once made, shall apply to
the taxable year for which made and all subsequent taxable years unless revoked with the
consent of the Secretary.
(g) Regulatory authority
The Secretary shall prescribe such regulations
as may be necessary or appropriate to carry out
the purposes of this section, including rules—
(1) to prevent the use of year-end transfers,
related parties, or other arrangements to
avoid the provisions of this section,
(2) to provide for the application of this section to any security which is a hedge which
cannot be identified with a specific security,
position, right to income, or liability, and
(3) to prevent the use by taxpayers of subsection (c)(4) to avoid the application of this
section to a receivable that is inventory in the
hands of the taxpayer (or a person who bears
a relationship to the taxpayer described in
section 267(b) or 707(b)).
(Added Pub. L. 103–66, title XIII, § 13223(a), Aug.
10, 1993, 107 Stat. 481; amended Pub. L. 105–34,
title X, § 1001(b), Aug. 5, 1997, 111 Stat. 906; Pub.
L. 105–206, title VI, § 6010(a)(3), title VII, § 7003(a),
(b), July 22, 1998, 112 Stat. 813, 832; Pub. L.
106–170, title V, § 532(b)(1), Dec. 17, 1999, 113 Stat.
1930; Pub. L. 106–554, § 1(a)(7) [title III, § 319(4)],
Dec. 21, 2000, 114 Stat. 2763, 2763A–646; Pub. L.
107–147, title IV, § 417(10), Mar. 9, 2002, 116 Stat.
56.)
AMENDMENTS
2002—Subsec. (g)(3). Pub. L. 107–147 substituted ‘‘described in section’’ for ‘‘described in sections’’.
2000—Subsec. (g)(3). Pub. L. 106–554 substituted ‘‘267(b)
or’’ for ‘‘267(b) of’’.
1999—Subsec. (c)(3). Pub. L. 106–170 substituted ‘‘manages’’ for ‘‘reduces’’.
1998—Subsec. (c)(4). Pub. L. 105–206, § 7003(a), added
par. (4).
Subsec. (f)(1)(D). Pub. L. 105–206, § 6010(a)(3), inserted
at end ‘‘Subsection (d)(3) shall not apply under the preceding sentence for purposes of applying sections 1402
and 7704.’’
Subsec. (g)(3). Pub. L. 105–206, § 7003(b), added par. (3).
1997—Subsecs. (e) to (g). Pub. L. 105–34 added subsecs.
(e) and (f) and redesignated former subsec. (e) as (g).
EFFECTIVE DATE OF 1999 AMENDMENT
Amendment by Pub. L. 106–170 applicable to any instrument held, acquired, or entered into, any trans-

§ 475

TITLE 26—INTERNAL REVENUE CODE

action entered into, and supplies held or acquired on or
after Dec. 17, 1999, see section 532(d) of Pub. L. 106–170,
set out as a note under section 170 of this title.
EFFECTIVE DATE OF 1998 AMENDMENT
Amendment by section 6010(a)(3) of Pub. L. 105–206 effective, except as otherwise provided, as if included in
the provisions of the Taxpayer Relief Act of 1997, Pub.
L. 105–34, to which such amendment relates, see section
6024 of Pub. L. 105–206, set out as a note under section
1 of this title.
Pub. L. 105–206, title VII, § 7003(c), July 22, 1998, 112
Stat. 833, provided that:
‘‘(1) IN GENERAL.—The amendments made by this section [amending this section] shall apply to taxable
years ending after the date of the enactment of this
Act [July 22, 1998].
‘‘(2) CHANGE IN METHOD OF ACCOUNTING.—In the case of
any taxpayer required by the amendments made by this
section to change its method of accounting for its first
taxable year ending after the date of the enactment of
this Act—
‘‘(A) such change shall be treated as initiated by
the taxpayer;
‘‘(B) such change shall be treated as made with the
consent of the Secretary of the Treasury; and
‘‘(C) the net amount of the adjustments required to
be taken into account by the taxpayer under section
481 of the Internal Revenue Code of 1986 shall be
taken into account ratably over the 4-taxable-year
period beginning with such first taxable year.’’
EFFECTIVE DATE OF 1997 AMENDMENT
Pub. L. 105–34, title X, § 1001(d), Aug. 5, 1997, 111 Stat.
907, as amended by Pub. L. 105–206, title VI, § 6010(a)(4),
July 22, 1998, 112 Stat. 813, provided that:
‘‘(1) IN GENERAL.—Except as otherwise provided in
this subsection, the amendments made by this section
[enacting section 1259 of this title and amending this
section] shall apply to any constructive sale after June
8, 1997.
‘‘(2) EXCEPTION FOR SALES OF POSITIONS, ETC. HELD BEFORE JUNE 9, 1997.—If—
‘‘(A) before June 9, 1997, the taxpayer entered into
any transaction which is a constructive sale of any
appreciated financial position, and
‘‘(B) before the close of the 30-day period beginning
on the date of the enactment of this Act [Aug. 5, 1997]
or before such later date as may be specified by the
Secretary of the Treasury, such transaction and position are clearly identified in the taxpayer’s records as
offsetting,
such transaction and position shall not be taken into
account in determining whether any other constructive
sale after June 8, 1997, has occurred. The preceding sentence shall cease to apply as of the date such transaction is closed or the taxpayer ceases to hold such position.
‘‘(3) SPECIAL RULE.—In the case of a decedent dying
after June 8, 1997, if—
‘‘(A) there was a constructive sale on or before such
date of any appreciated financial position,
‘‘(B) the transaction resulting in such constructive
sale of such position remains open (with respect to
the decedent or any related person)—
‘‘(i) for not less than 2 years after the date of such
transaction (whether such period is before or after
June 8, 1997), and
‘‘(ii) at any time during the 3-year period ending
on the date of the decedent’s death, and
‘‘(C) such transaction is not closed before the close
of the 30th day after the date of the enactment of this
Act,
then, for purposes of such Code [probably means the Internal Revenue Code of 1986], such position (and the
transaction resulting in such constructive sale) shall be
treated as property constituting rights to receive an
item of income in respect of a decedent under section
691 of such Code. Section 1014(c) of such Code shall not

Page 1462

apply to so much of such position’s or property’s value
(as included in the decedent’s estate for purposes of
chapter 11 of such Code) as exceeds its fair market
value as of the date such transaction is closed.
‘‘(4) ELECTION OF MARK TO MARKET BY SECURITIES
TRADERS AND TRADERS AND DEALERS IN COMMODITIES.—
‘‘(A) IN GENERAL.—The amendments made by subsection (b) [amending this section] shall apply to taxable years ending after the date of the enactment of
this Act.
‘‘(B) 4-YEAR SPREAD OF ADJUSTMENTS.—In the case
of a taxpayer who elects under subsection (e) or (f) of
section 475 of the Internal Revenue Code of 1986 (as
added by this section) to change its method of accounting for the taxable year which includes the date
of the enactment of this Act—
‘‘(i) any identification required under such subsection with respect to securities and commodities
held on the date of the enactment of this Act shall
be treated as timely made if made on or before the
30th day after such date of enactment, and
‘‘(ii) the net amount of the adjustments required
to be taken into account by the taxpayer under section 481 of such Code shall be taken into account
ratably over the 4-taxable year period beginning
with such first taxable year.’’
EFFECTIVE DATE
Pub. L. 103–66, title XIII, § 13223(c), Aug. 10, 1993, 107
Stat. 484, provided that:
‘‘(1) IN GENERAL.—The amendments made by this section [enacting this section and amending section 988 of
this title] shall apply to all taxable years ending on or
after December 31, 1993.
‘‘(2) CHANGE IN METHOD OF ACCOUNTING.—In the case of
any taxpayer required by this section to change its
method of accounting for any taxable year—
‘‘(A) such change shall be treated as initiated by
the taxpayer,
‘‘(B) such change shall be treated as made with the
consent of the Secretary, and
‘‘(C) except as provided in paragraph (3), the net
amount of the adjustments required to be taken into
account by the taxpayer under section 481 of the Internal Revenue Code of 1986 shall be taken into account ratably over the 5-taxable year period beginning with the first taxable year ending on or after
December 31, 1993.
‘‘(3) SPECIAL RULE FOR FLOOR SPECIALISTS AND MARKET
MAKERS.—
‘‘(A) IN GENERAL.—If—
‘‘(i) a taxpayer (or any predecessor) used the lastin first-out (LIFO) method of accounting with respect to any qualified securities for the 5-taxable
year period ending with its last taxable year ending
before December 31, 1993, and
‘‘(ii) any portion of the net amount described in
paragraph (2)(C) is attributable to the use of such
method of accounting,
then paragraph (2)(C) shall be applied by taking such
portion into account ratably over the 15-taxable year
period beginning with the first taxable year ending
on or after December 31, 1993.
‘‘(B) QUALIFIED SECURITY.—For purposes of this
paragraph, the term ‘qualified security’ means any
security acquired—
‘‘(i) by a floor specialist (as defined in section
1236(d)(2) of the Internal Revenue Code of 1986) in
connection with the specialist’s duties as a specialist on an exchange, but only if the security is one
in which the specialist is registered with the exchange, or
‘‘(ii) by a taxpayer who is a market maker in connection with the taxpayer’s duties as a market
maker, but only if—
‘‘(I) the security is included on the National Association
of
Security
Dealers
Automated
Quotation System,
‘‘(II) the taxpayer is registered as a market
maker in such security with the National Association of Security Dealers, and

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TITLE 26—INTERNAL REVENUE CODE

‘‘(III) as of the last day of the taxable year preceding the taxpayer’s first taxable year ending on
or after December 31, 1993, the taxpayer (or any
predecessor) has been actively and regularly engaged as a market maker in such security for the
2-year period ending on such date (or, if shorter,
the period beginning 61 days after the security
was listed in such quotation system and ending
on such date).’’

PART III—ADJUSTMENTS
Sec.

481.
482.
483.

Adjustments required by changes in method
of accounting.
Allocation of income and deductions among
taxpayers.
Interest on certain deferred payments.
AMENDMENTS

1964—Pub. L. 88–272, title II, § 224(b), Feb. 26, 1964, 78
Stat. 79, added item 483.

§ 481. Adjustments required by changes in method of accounting
(a) General rule
In computing the taxpayer’s taxable income
for any taxable year (referred to in this section
as the ‘‘year of the change’’)—
(1) if such computation is under a method of
accounting different from the method under
which the taxpayer’s taxable income for the
preceding taxable year was computed, then
(2) there shall be taken into account those
adjustments which are determined to be necessary solely by reason of the change in order
to prevent amounts from being duplicated or
omitted, except there shall not be taken into
account any adjustment in respect of any taxable year to which this section does not apply
unless the adjustment is attributable to a
change in the method of accounting initiated
by the taxpayer.
(b) Limitation on tax where adjustments are substantial
(1) Three year allocation
If—
(A) the method of accounting from which
the change is made was used by the taxpayer
in computing his taxable income for the 2
taxable years preceding the year of the
change, and
(B) the increase in taxable income for the
year of the change which results solely by
reason of the adjustments required by subsection (a)(2) exceeds $3,000,
then the tax under this chapter attributable to
such increase in taxable income shall not be
greater than the aggregate increase in the
taxes under this chapter (or under the corresponding provisions of prior revenue laws)
which would result if one-third of such increase in taxable income were included in taxable income for the year of the change and
one-third of such increase were included for
each of the 2 preceding taxable years.
(2) Allocation under new method of accounting
If—
(A) the increase in taxable income for the
year of the change which results solely by
reason of the adjustments required by subsection (a)(2) exceeds $3,000, and

§ 481

(B) the taxpayer establishes his taxable income (under the new method of accounting)
for one or more taxable years consecutively
preceding the taxable year of the change for
which the taxpayer in computing taxable income used the method of accounting from
which the change is made,
then the tax under this chapter attributable to
such increase in taxable income shall not be
greater than the net increase in the taxes
under this chapter (or under the corresponding
provisions of prior revenue laws) which would
result if the adjustments required by subsection (a)(2) were allocated to the taxable
year or years specified in subparagraph (B) to
which they are properly allocable under the
new method of accounting and the balance of
the adjustments required by subsection (a)(2)
was allocated to the taxable year of the
change.
(3) Special rules for computations under paragraphs (1) and (2)
For purposes of this subsection—
(A) There shall be taken into account the
increase or decrease in tax for any taxable
year preceding the year of the change to
which no adjustment is allocated under
paragraph (1) or (2) but which is affected by
a net operating loss (as defined in section
172) or by a capital loss carryback or carryover (as defined in section 1212), determined
with reference to taxable years with respect
to which adjustments under paragraph (1) or
(2) are allocated.
(B) The increase or decrease in the tax for
any taxable year for which an assessment of
any deficiency, or a credit or refund of any
overpayment, is prevented by any law or
rule of law, shall be determined by reference
to the tax previously determined (within the
meaning of section 1314(a)) for such year.
(C) In applying section 7807(b)(1), the provisions of chapter 1 (other than subchapter
E, relating to self-employment income) and
chapter 2 of the Internal Revenue Code of
1939 shall be treated as the corresponding
provisions of the Internal Revenue Code of
1939.
(c) Adjustments under regulations
In the case of any change described in subsection (a), the taxpayer may, in such manner
and subject to such conditions as the Secretary
may by regulations prescribe, take the adjustments required by subsection (a)(2) into account
in computing the tax imposed by this chapter
for the taxable year or years permitted under
such regulations.
(Aug. 16, 1954, ch. 736, 68A Stat. 160; Pub. L.
85–866, title I, § 29(a), (b), Sept. 2, 1958, 72 Stat.
1626–1628; Pub. L. 91–172, title V, § 512(f)(4), Dec.
30, 1969, 83 Stat. 641; Pub. L. 94–455, title XIX,
§§ 1901(a)(70), 1906(b)(13)(A), Oct. 4, 1976, 90 Stat.
1776, 1834; Pub. L. 96–471, § 2(b)(3), Oct. 19, 1980, 94
Stat. 2254.)
REFERENCES IN TEXT
The Internal Revenue Code of 1939, referred to in subsec. (b)(3)(C), is act Feb. 10, 1939, ch. 2, 53 Stat. 1, as
amended. Prior to the enactment of the Internal Reve-