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26 U.S.C. § 1033 — Involuntary conversions

Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 1033 — Involuntary conversions

**(a) General rule** If property (as a result of its destruction in whole or in part, theft, seizure, or requisition or condemnation or threat or imminence thereof) is compulsorily or involuntarily converted— (1) **Conversion into similar property** — Into property similar or related in service or use to the property so converted, no gain shall be recognized. (2) **Conversion into money** — Into money or into property not similar or related in service or use to the converted property, the gain (if any) shall be recognized except to the extent hereinafter provided in this paragraph: (A) *Nonrecognition of gain* — If the taxpayer during the period specified in subparagraph (B), for the purpose of replacing the property so converted, purchases other property similar or related in service or use to the property so converted, or purchases stock in the acquisition of control of a corporation owning such other property, at the election of the taxpayer the gain shall be recognized only to the extent that the amount realized upon such conversion (regardless of whether such amount is received in one or more taxable years) exceeds the cost of such other property or such stock. Such election shall be made at such time and in such manner as the Secretary may by regulations prescribe. For purposes of this paragraph— (i) no property or stock acquired before the disposition of the converted property shall be considered to have been acquired for the purpose of replacing such converted property unless held by the taxpayer on the date of such disposition; and (ii) the taxpayer shall be considered to have purchased property or stock only if, but for the provisions of subsection (b) of this section, the unadjusted basis of such property or stock would be its cost within the m

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**(a) General rule** If property (as a result of its destruction in whole or in part, theft, seizure, or requisition or condemnation or threat or imminence thereof) is compulsorily or involuntarily converted— (1) **Conversion into similar property** — Into property similar or related in service or use to the property so converted, no gain shall be recognized. (2) **Conversion into money** — Into money or into property not similar or related in service or use to the converted property, the gain (if any) shall be recognized except to the extent hereinafter provided in this paragraph: (A) *Nonrecognition of gain* — If the taxpayer during the period specified in subparagraph (B), for the purpose of replacing the property so converted, purchases other property similar or related in service or use to the property so converted, or purchases stock in the acquisition of control of a corporation owning such other property, at the election of the taxpayer the gain shall be recognized only to the extent that the amount realized upon such conversion (regardless of whether such amount is received in one or more taxable years) exceeds the cost of such other property or such stock. Such election shall be made at such time and in such manner as the Secretary may by regulations prescribe. For purposes of this paragraph— (i) no property or stock acquired before the disposition of the converted property shall be considered to have been acquired for the purpose of replacing such converted property unless held by the taxpayer on the date of such disposition; and (ii) the taxpayer shall be considered to have purchased property or stock only if, but for the provisions of subsection (b) of this section, the unadjusted basis of such property or stock would be its cost within the meaning of section 1012. (B) *Period within which property must be replaced* — The period referred to in subparagraph (A) shall be the period beginning with the date of the disposition of the converted property, or the earliest date of the threat or imminence of requisition or condemnation of the converted property, whichever is the earlier, and ending— (i) 2 years after the close of the first taxable year in which any part of the gain upon the conversion is realized, or (ii) subject to such terms and conditions as may be specified by the Secretary, at the close of such later date as the Secretary may designate on application by the taxpayer. Such application shall be made at such time and in such manner as the Secretary may by regulations prescribe. (C) *Time for assessment of deficiency attributable to gain upon conversion* — If a taxpayer has made the election provided in subparagraph (A), then— (i) the statutory period for the assessment of any deficiency, for any taxable year in which any part of the gain on such conversion is realized, attributable to such gain shall not expire prior to the expiration of 3 years from the date the Secretary is notified by the taxpayer (in such manner as the Secretary may by regulations prescribe) of the replacement of the converted property or of an intention not to replace, and (ii) such deficiency may be assessed before the expiration of such 3–year period notwithstanding the provisions of section 6212(c) or the provisions of any other law or rule of law which would otherwise prevent such assessment. (D) *Time for assessment of other deficiencies attributable to election* — If the election provided in subparagraph (A) is made by the taxpayer and such other property or such stock was purchased before the beginning of the last taxable year in which any part of the gain upon such conversion is realized, any deficiency, to the extent resulting from such election, for any taxable year ending before such last taxable year may be assessed (notwithstanding the provisions of section 6212(c) or 6501 or the provisions of any other law or rule of law which would otherwise prevent such assessment) at any time before the expiration of the period within which a deficiency for such last taxable year may be assessed. (E) *Definitions* — For purposes of this paragraph— (i) *Control* — The term “control” means the ownership of stock possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote and at least 80 percent of the total number of shares of all other classes of stock of the corporation. (ii) *Disposition of the converted property* — The term “disposition of the converted property” means the destruction, theft, seizure, requisition, or condemnation of the converted property, or the sale or exchange of such property under threat or imminence of requisition or condemnation. **(b) Basis of property acquired through involuntary conversion** (1) **Conversions described in subsection (a)(1)** — If the property was acquired as the result of a compulsory or involuntary conversion described in subsection (a)(1), the basis shall be the same as in the case of the property so converted— (A) decreased in the amount of any money received by the taxpayer which was not expended in accordance with the provisions of law (applicable to the year in which such conversion was made) determining the taxable status of the gain or loss upon such conversion, and (B) increased in the amount of gain or decreased in the amount of loss to the taxpayer recognized upon such conversion under the law applicable to the year in which such conversion was made. (2) **Conversions described in subsection (a)(2)** — In the case of property purchased by the taxpayer in a transaction described in subsection (a)(2) which resulted in the nonrecognition of any part of the gain realized as the result of a compulsory or involuntary conversion, the basis shall be the cost of such property decreased in the amount of the gain not so recognized; and if the property purchased consists of more than 1 piece of property, the basis determined under this sentence shall be allocated to the purchased properties in proportion to their respective costs. (3) **Property held by corporation the stock of which is replacement property** (A) *In general* — If the basis of stock in a corporation is decreased under paragraph (2), an amount equal to such decrease shall also be applied to reduce the basis of property held by the corporation at the time the taxpayer acquired control (as defined in subsection (a)(2)(E)) of such corporation. (B) *Limitation* — Subparagraph (A) shall not apply to the extent that it would (but for this subparagraph) require a reduction in the aggregate adjusted bases of the property of the corporation below the taxpayer’s adjusted basis of the stock in the corporation (determined immediately after such basis is decreased under paragraph (2)). (C) *Allocation of basis reduction* — The decrease required under subparagraph (A) shall be allocated— (i) first to property which is similar or related in service or use to the converted property, (ii) second to depreciable property (as defined in section 1017(b)(3)(B)) not described in clause (i), and (iii) then to other property. (D) *Special rules* (i) *Reduction not to exceed adjusted basis of property* — No reduction in the basis of any property under this paragraph shall exceed the adjusted basis of such property (determined without regard to such reduction). (ii) *Allocation of reduction among properties* — If more than 1 property is described in a clause of subparagraph (C), the reduction under this paragraph shall be allocated among such property in proportion to the adjusted bases of such property (as so determined). **(c) Property sold pursuant to reclamation laws** For purposes of this subtitle, if property lying within an irrigation project is sold or otherwise disposed of in order to conform to the acreage limitation provisions of Federal reclamation laws, such sale or disposition shall be treated as an involuntary conversion to which this section applies. **(d) Livestock destroyed by disease** For purposes of this subtitle, if livestock are destroyed by or on account of disease, or are sold or exchanged because of disease, such destruction or such sale or exchange shall be treated as an involuntary conversion to which this section applies. **(e) Livestock sold on account of drought, flood, or other weather-related conditions** (1) **In general** — For purposes of this subtitle, the sale or exchange of livestock (other than poultry) held by a taxpayer for draft, breeding, or dairy purposes in excess of the number the taxpayer would sell if he followed his usual business practices shall be treated as an involuntary conversion to which this section applies if such livestock are sold or exchanged by the taxpayer solely on account of drought, flood, or other weather-related conditions. (2) **Extension of replacement period** (A) *In general* — In the case of drought, flood, or other weather-related conditions described in paragraph (1) which result in the area being designated as eligible for assistance by the Federal Government, subsection (a)(2)(B) shall be applied with respect to any converted property by substituting “4 years” for “2 years”. (B) *Further extension by Secretary* — The Secretary may extend on a regional basis the period for replacement under this section (after the application of subparagraph (A)) for such additional time as the Secretary determines appropriate if the weather-related conditions which resulted in such application continue for more than 3 years. **(f) Replacement of livestock with other farm property in certain cases** For purposes of subsection (a), if, because of drought, flood, or other weather-related conditions, or soil contamination or other environmental contamination, it is not feasible for the taxpayer to reinvest the proceeds from compulsorily or involuntarily converted livestock in property similar or related in use to the livestock so converted, other property (including real property in the case of soil contamination or other environmental contamination) used for farming purposes shall be treated as property similar or related in service or use to the livestock so converted. **(g) Condemnation of real property held for productive use in trade or business or for investment** (1) **Special rule** — For purposes of subsection (a), if real property (not including stock in trade or other property held primarily for sale) held for productive use in trade or business or for investment is (as the result of its seizure, requisition, or condemnation, or threat or imminence thereof) compulsorily or involuntarily converted, property of a like kind to be held either for productive use in trade or business or for investment shall be treated as property similar or related in service or use to the property so converted. (2) **Limitations** — Paragraph (1) shall not apply to the purchase of stock in the acquisition of control of a corporation described in subsection (a)(2)(A). (3) **Election to treat outdoor advertising displays as real property** (A) *In general* — A taxpayer may elect, at such time and in such manner as the Secretary may prescribe, to treat property which constitutes an outdoor advertising display as real property for purposes of this chapter. The election provided by this subparagraph may not be made with respect to any property with respect to which an election under section 179(a) (relating to election to expense certain depreciable business assets) is in effect. (B) *Election* — An election made under subparagraph (A) may not be revoked without the consent of the Secretary. (C) *Outdoor advertising display* — For purposes of this paragraph, the term “outdoor advertising display” means a rigidly assembled sign, display, or device permanently affixed to the ground or permanently attached to a building or other inherently permanent structure constituting, or used for the display of, a commercial or other advertisement to the public. (D) *Character of replacement property* — For purposes of this subsection, an interest in real property purchased as replacement property for a compulsorily or involuntarily converted outdoor advertising display defined in subparagraph (C) (and treated by the taxpayer as real property) shall be considered property of a like kind as the property converted without regard to whether the taxpayer’s interest in the replacement property is the same kind of interest the taxpayer held in the converted property. (4) **Special rule** — In the case of a compulsory or involuntary conversion described in paragraph (1), subsection (a)(2)(B)(i) shall be applied by substituting “3 years” for “2 years”. **(h) Special rules for property damaged by federally declared disasters** (1) **Principal residences** — If the taxpayer’s principal residence or any of its contents is located in a disaster area and is compulsorily or involuntarily converted as a result of a federally declared disaster— (A) *Treatment of insurance proceeds* (i) *Exclusion for unscheduled personal property* — No gain shall be recognized by reason of the receipt of any insurance proceeds for personal property which was part of such contents and which was not scheduled property for purposes of such insurance. (ii) *Other proceeds treated as common fund* — In the case of any insurance proceeds (not described in clause (i)) for such residence or contents— (I) such proceeds shall be treated as received for the conversion of a single item of property, and (II) any property which is similar or related in service or use to the residence so converted (or contents thereof) shall be treated for purposes of subsection (a)(2) as property similar or related in service or use to such single item of property. (B) *Extension of replacement period* — Subsection (a)(2)(B) shall be applied with respect to any property so converted by substituting “4 years” for “2 years”. (2) **Trade or business and investment property** — If a taxpayer’s property held for productive use in a trade or business or for investment is located in a disaster area and is compulsorily or involuntarily converted as a result of a federally declared disaster, tangible property of a type held for productive use in a trade or business shall be treated for purposes of subsection (a) as property similar or related in service or use to the property so converted. (3) **Federally declared disaster; disaster area** — The terms “federally declared disaster” and “disaster area” shall have the respective meaning given such terms by section 165(i)(5). (4) **Principal residence** — For purposes of this subsection, the term “principal residence” has the same meaning as when used in section 121, except that such term shall include a residence not treated as a principal residence solely because the taxpayer does not own the residence. **(i) Replacement property must be acquired from unrelated person in certain cases** (1) **In general** — If the property which is involuntarily converted is held by a taxpayer to which this subsection applies, subsection (a) shall not apply if the replacement property or stock is acquired from a related person. The preceding sentence shall not apply to the extent that the related person acquired the replacement property or stock from an unrelated person during the period applicable under subsection (a)(2)(B). (2) **Taxpayers to which subsection applies** — This subsection shall apply to— (A) a C corporation, (B) a partnership in which 1 or more C corporations own, directly or indirectly (determined in accordance with section 707(b)(3)), more than 50 percent of the capital interest, or profits interest, in such partnership at the time of the involuntary conversion, and (C) any other taxpayer if, with respect to property which is involuntarily converted during the taxable year, the aggregate of the amount of realized gain on such property on which there is realized gain exceeds $100,000. In the case of a partnership, subparagraph (C) shall apply with respect to the partnership and with respect to each partner. A similar rule shall apply in the case of an S corporation and its shareholders. (3) **Related person** — For purposes of this subsection, a person is related to another person if the person bears a relationship to the other person described in section 267(b) or 707(b)(1). **(j) Sales or exchanges under certain hazard mitigation programs** For purposes of this subtitle, if property is sold or otherwise transferred to the Federal Government, a State or local government, or an Indian tribal government to implement hazard mitigation under the Robert T. Stafford Disaster Relief and Emergency Assistance Act (as in effect on the date of the enactment of this subsection) or the National Flood Insurance Act (as in effect on such date), such sale or transfer shall be treated as an involuntary conversion to which this section applies. **(k) Cross references** (1) For determination of the period for which the taxpayer has held property involuntarily converted, see section 1223. (2) For treatment of gains from involuntary conversions as capital gains in certain cases, see section 1231(a). (3) For exclusion from gross income of gain from involuntary conversion of principal residence, see section 121.

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Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 165 — Losses

**(a) General rule** There shall be allowed as a deduction any loss sustained during the taxable year and not compensated for by insurance or otherwise. **(b) Amount of deduction** For purposes of subsection (a), the basis for determining the amount of the deduction for any loss shall be the adjusted basis provided in section 1011 for determining the loss from the sale or other disposition of property. **(c) Limitation on losses of individuals** In the case of an individual, the deduction under subsection (a) shall be limited to— (1) losses incurred in a trade or business; (2) losses incurred in any transaction entered into for profit, though not connected with a trade or business; and (3) except as provided in subsection (h), losses of property not connected with a trade or business or a transaction entered into for profit, if such losses arise from fire, storm, shipwreck, or other casualty, or from theft. **(d) Wagering losses** (1) **In general** — For purposes of losses from wagering transactions, the amount allowed as a deduction for any taxable year— (A) shall be equal to 90 percent of the amount of such losses during such taxable year, and (B) shall be allowed only to the extent of the gains from such transactions during such taxable year. (2) **Special rule** — For purposes of paragraph (1), the term “losses from wagering transactions” includes any deduction otherwise allowable under this chapter incurred in carrying on any wagering transaction. **(e) Theft losses** For purposes of subsection (a), any loss arising from theft shall be treated as sustained during the taxable year in which the taxpayer discovers such loss. **(f) Capital losses** Losses from sales or exchanges of capital assets shall be allowed only to the extent allowed in sections

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26 U.S.C. § 46 — Amount of credit

For purposes of section 38, the amount of the investment credit determined under this section for any taxable year shall be the sum of— (1) the rehabilitation credit, (2) the energy credit, (3) the qualifying advanced coal project credit, (4) the qualifying gasification project credit, (5) the qualifying advanced energy project credit, (6) the advanced manufacturing investment credit, and (7) the clean electricity investment credit.

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26 U.S.C. § 143 — Mortgage revenue bonds: qualified mortgage bond and qualified veterans’ mortgage bond

**(a) Qualified mortgage bond** (1) **Qualified mortgage bond defined** — For purposes of this title, the term “qualified mortgage bond” means a bond which is issued as part of a qualified mortgage issue. (2) **Qualified mortgage issue defined** (A) *Definition* — For purposes of this title, the term “qualified mortgage issue” means an issue by a State or political subdivision thereof of 1 or more bonds, but only if— (i) all proceeds of such issue (exclusive of issuance costs and a reasonably required reserve) are to be used to finance owner-occupied residences, (ii) such issue meets the requirements of subsections (c), (d), (e), (f), (g), (h), (i), and (m)(7), (iii) such issue does not meet the private business tests of paragraphs (1) and (2) of section 141(b), and (iv) except as provided in subparagraph (D)(ii), repayments of principal on financing provided by the issue are used not later than the close of the 1st semiannual period beginning after the date the prepayment (or complete repayment) is received to redeem bonds which are part of such issue. Clause (iv) shall not apply to amounts received within 10 years after the date of issuance of the issue (or, in the case of refunding bond, the date of issuance of the original bond). (B) *Good faith effort to comply with mortgage eligibility requirements* — An issue which fails to meet 1 or more of the requirements of subsections (c), (d), (e), (f), and (i) shall be treated as meeting such requirements if— (i) the issuer in good faith attempted to meet all such requirements before the mortgages were executed, (ii) 95 percent or more of the proceeds devoted to owner-financing was devoted to residences with respect to which (at the time the mortgages were executed) all such requir

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Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 121 — Exclusion of gain from sale of principal residence

**(a) Exclusion** Gross income shall not include gain from the sale or exchange of property if, during the 5-year period ending on the date of the sale or exchange, such property has been owned and used by the taxpayer as the taxpayer’s principal residence for periods aggregating 2 years or more. **(b) Limitations** (1) **In general** — The amount of gain excluded from gross income under subsection (a) with respect to any sale or exchange shall not exceed $250,000. (2) **Special rules for joint returns** — In the case of a husband and wife who make a joint return for the taxable year of the sale or exchange of the property— (A) *$500,000 Limitation for certain joint returns* — Paragraph (1) shall be applied by substituting “$500,000” for “$250,000” if— (i) either spouse meets the ownership requirements of subsection (a) with respect to such property; (ii) both spouses meet the use requirements of subsection (a) with respect to such property; and (iii) neither spouse is ineligible for the benefits of subsection (a) with respect to such property by reason of paragraph (3). (B) *Other joint returns* — If such spouses do not meet the requirements of subparagraph (A), the limitation under paragraph (1) shall be the sum of the limitations under paragraph (1) to which each spouse would be entitled if such spouses had not been married. For purposes of the preceding sentence, each spouse shall be treated as owning the property during the period that either spouse owned the property. (3) **Application to only 1 sale or exchange every 2 years** — Subsection (a) shall not apply to any sale or exchange by the taxpayer if, during the 2-year period ending on the date of such sale or exchange, there was any other sale or exchange by the taxpayer to which subsec

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26 U.S.C. § 56 — Adjustments in computing alternative minimum taxable income

**(a) Adjustments applicable to all taxpayers** In determining the amount of the alternative minimum taxable income for any taxable year the following treatment shall apply (in lieu of the treatment applicable for purposes of computing the regular tax): (1) **Depreciation** (A) *In general* (i) *Property other than certain personal property* — Except as provided in clause (ii), the depreciation deduction allowable under section 167 with respect to any tangible property placed in service after December 31, 1986, shall be determined under the alternative system of section 168(g). In the case of property placed in service after December 31, 1998, the preceding sentence shall not apply but clause (ii) shall continue to apply. (ii) *150-percent declining balance method for certain property* — The method of depreciation used shall be— (I) the 150 percent declining balance method, (II) switching to the straight line method for the 1st taxable year for which using the straight line method with respect to the adjusted basis as of the beginning of the year will yield a higher allowance. The preceding sentence shall not apply to any section 1250 property (as defined in section 1250(c)) (and the straight line method shall be used for such section 1250 property) or to any other property if the depreciation deduction determined under section 168 with respect to such other property for purposes of the regular tax is determined by using the straight line method. (B) *Exception for certain property* — This paragraph shall not apply to property described in paragraph (1), (2), (3), or (4) of section 168(f), or in section 168(e)(3)(C)(iv). (C) *Coordination with transitional rules* (i) *In general* — This paragraph shall not apply to property pla

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42 U.S.C. § 5121 — Congressional findings and declarations

**(a)** The Congress hereby finds and declares that— (1) because disasters often cause loss of life, human suffering, loss of income, and property loss and damage; and (2) because disasters often disrupt the normal functioning of governments and communities, and adversely affect individuals and families with great severity; special measures, designed to assist the efforts of the affected States in expediting the rendering of aid, assistance, and emergency services, and the reconstruction and rehabilitation of devastated areas, are necessary. **(b)** It is the intent of the Congress, by this chapter, to provide an orderly and continuing means of assistance by the Federal Government to State and local governments in carrying out their responsibilities to alleviate the suffering and damage which result from such disasters by— (1) revising and broadening the scope of existing disaster relief programs; (2) encouraging the development of comprehensive disaster preparedness and assistance plans, programs, capabilities, and organizations by the States and by local governments; (3) achieving greater coordination and responsiveness of disaster preparedness and relief programs; (4) encouraging individuals, States, and local governments to protect themselves by obtaining insurance coverage to supplement or replace governmental assistance; (5) encouraging hazard mitigation measures to reduce losses from disasters, including development of land use and construction regulations; (6) providing Federal assistance programs for both public and private losses sustained in disasters; and (7) identifying and improving the climate and natural hazard resilience of vulnerable communities.

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42 U.S.C. § 4001 — Authorization of appropriations; availability

**(a)** There are hereby authorized to be appropriated such sums as may from time to time be necessary to carry out this chapter, including sums— (1) to cover administrative expenses authorized under [section 4126 of this title](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title42-section4126&num=0&edition=prelim); (2) to reimburse the National Flood Insurance Fund established under [section 4017 of this title](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title42-section4017&num=0&edition=prelim) for— (A) premium equalization payments under [section 4054 of this title](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title42-section4054&num=0&edition=prelim) which have been made from such fund; and (B) reinsurance claims paid under the excess loss reinsurance coverage provided under [section 4055 of this title](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title42-section4055&num=0&edition=prelim); and (3) to make such other payments as may be necessary to carry out the purposes of this chapter. **(b)** All such funds shall be available without fiscal year limitation. **(c)** There are authorized to be appropriated such sums as may be necessary through the date specified in [section 4026 of this title](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title42-section4026&num=0&edition=prelim), for studies under this chapter.

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26 U.S.C. § 168 — Accelerated cost recovery system

**(a) General rule** Except as otherwise provided in this section, the depreciation deduction provided by section 167(a) for any tangible property shall be determined by using— (1) the applicable depreciation method, (2) the applicable recovery period, and (3) the applicable convention. **(b) Applicable depreciation method** For purposes of this section— (1) **In general** — Except as provided in paragraphs (2) and (3), the applicable depreciation method is— (A) the 200 percent declining balance method, (B) switching to the straight line method for the 1st taxable year for which using the straight line method with respect to the adjusted basis as of the beginning of such year will yield a larger allowance. (2) **150 percent declining balance method in certain cases** — Paragraph (1) shall be applied by substituting “150 percent” for “200 percent” in the case of— (A) any 15-year or 20-year property not referred to in paragraph (3), (B) any property (other than property described in paragraph (3)) which is a qualified smart electric meter or qualified smart electric grid system, or (C) any property (other than property described in paragraph (3)) with respect to which the taxpayer elects under paragraph (5) to have the provisions of this paragraph apply. (3) **Property to which straight line method applies** — The applicable depreciation method shall be the straight line method in the case of the following property: (A) Nonresidential real property. (B) Residential rental property. (C) Any railroad grading or tunnel bore. (D) Property with respect to which the taxpayer elects under paragraph (5) to have the provisions of this paragraph apply. (E) Property described in subsection (e)(3)(D)(ii). (F) Water utility property described in

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Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 451 — General rule for taxable year of inclusion

**(a) General rule** The amount of any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under the method of accounting used in computing taxable income, such amount is to be properly accounted for as of a different period. **(b) Inclusion not later than for financial accounting purposes** (1) **Income taken into account in financial statement** (A) *In general* — In the case of a taxpayer the taxable income of which is computed under an accrual method of accounting, the all events test with respect to any item of gross income (or portion thereof) shall not be treated as met any later than when such item (or portion thereof) is taken into account as revenue in— (i) an applicable financial statement of the taxpayer, or (ii) such other financial statement as the Secretary may specify for purposes of this subsection. (B) *Exception* — This paragraph shall not apply to— (i) a taxpayer which does not have a financial statement described in clause (i) or (ii) of subparagraph (A) for a taxable year, or (ii) any item of gross income in connection with a mortgage servicing contract. (C) *All events test* — For purposes of this section, the all events test is met with respect to any item of gross income if all the events have occurred which fix the right to receive such income and the amount of such income can be determined with reasonable accuracy. (2) **Coordination with special methods of accounting** — Paragraph (1) shall not apply with respect to any item of gross income for which the taxpayer uses a special method of accounting provided under any other provision of this chapter, other than any provision of part V of subchapter P (except as provided in clause (ii) of para

Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 451

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Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 1 — Tax imposed

**(a) Married individuals filing joint returns and surviving spouses** There is hereby imposed on the taxable income of— (1) every married individual (as defined in section 7703) who makes a single return jointly with his spouse under section 6013, and (2) every surviving spouse (as defined in section 2(a)), a tax determined in accordance with the following table: If taxable income is:The tax is: Not over $36,90015% of taxable income. Over $36,900 but not over $89,150$5,535, plus 28% of the excess over $36,900. Over $89,150 but not over $140,000$20,165, plus 31% of the excess over $89,150. Over $140,000 but not over $250,000$35,928.50, plus 36% of the excess over $140,000. Over $250,000$75,528.50, plus 39.6% of the excess over $250,000. **(b) Heads of households** There is hereby imposed on the taxable income of every head of a household (as defined in section 2(b)) a tax determined in accordance with the following table: If taxable income is:The tax is: Not over $29,60015% of taxable income. Over $29,600 but not over $76,400$4,440, plus 28% of the excess over $29,600. Over $76,400 but not over $127,500$17,544, plus 31% of the excess over $76,400. Over $127,500 but not over $250,000$33,385, plus 36% of the excess over $127,500. Over $250,000$77,485, plus 39.6% of the excess over $250,000. **(c) Unmarried individuals (other than surviving spouses and heads of households)** There is hereby imposed on the taxable income of every individual (other than a surviving spouse as defined in section 2(a) or the head of a household as defined in section 2(b)) who is not a married individual (as defined in section 7703) a tax determined in accordance with the following table: If taxable income is:The tax is: Not over $22,10015% of taxable income. Over $22,100 but not over $53,50

Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 1

Stored review status: release_metadata_unconfirmed. Explicit cross-reference supplied in source Markdown; currentness and applicability require review.