‘‘(6) TAXABLE
PARTNER.—The term ‘taxable 
partner’ means, with respect to any partnership, any 
partner of such partnership which is not a tax-ex-
empt partner.’’. 
(3) Subsection (h) of section 470, as redesig-
nated by paragraph (1), is amended— 
(A) by striking ‘‘, and’’ at the end of para-
graph (1) and inserting ‘‘or owned by the same 
partnership,’’, 
(B) by striking the period at the end of 
paragraph (2) and inserting a comma, and 
(C) by adding at the end the following new 
paragraphs: 
‘‘(3) provide for the application of this section 
to tiered and other related partnerships, and 
‘‘(4) provide for the treatment of partnership 
property (other than property described in sub-
section (e)(1)(A)) as tax-exempt use property if such 
property is used in an arrangement which is incon-
sistent with the purposes of this section determined 
by taking into account one or more of the following 
factors: 
‘‘(A) A tax-exempt partner maintains phys-
ical possession or control or holds the benefits 
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and burdens of ownership with respect to such 
property. 
‘‘(B) There is insignificant equity invest-
ment in such property by any taxable partner. 
‘‘(C) The transfer of such property to the 
partnership does not result in a change in use 
of such property. 
‘‘(D) Such property is necessary for the 
provision of government services. 
‘‘(E) The deductions for depreciation with 
respect to such property are allocated dis-
proportionately to one or more taxable partners 
relative to such partner’s risk of loss with re-
spect to such property or to such partner’s allo-
cation of other partnership items. 
‘‘(F) Such other factors as the Secretary 
may determine.’’. 
(4) Paragraph (2) of section 470(c) is amend-
ed— 
(A) by striking ‘‘and’’ at the end of sub-
paragraph (A), by redesignating subparagraph 
(B) as subparagraph (C), and by inserting after 
subparagraph (A) the following new subpara-
graph: 
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‘‘(B) by treating the entire property as 
tax-exempt use property if any portion of such 
property is treated as tax-exempt use property 
by reason of paragraph (6) thereof.’’, and 
(B) by striking the flush sentence at the 
end. 
(5) Subparagraph (A) of section 470(d)(1) is 
amended by striking ‘‘(at any time during the lease 
term)’’ and inserting ‘‘(at all times during the lease 
term)’’. 
(c) AMENDMENTS RELATED TO SECTION 888 OF 
THE ACT.— 
(1) Subparagraph (A) of section 1092(a)(2) is 
amended by striking ‘‘and’’ at the end of clause (ii), 
by redesignating clause (iii) as clause (iv), and by in-
serting after clause (ii) the following new clause: 
‘‘(iii) if the application of clause (ii) 
does not result in an increase in the basis 
of any offsetting position in the identified 
straddle, the basis of each of the offsetting 
positions in the identified straddle shall be 
increased in a manner which— 
‘‘(I) is reasonable, consistent 
with the purposes of this paragraph, 
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and consistently applied by the tax-
payer, and 
‘‘(II) results in an aggregate in-
crease in the basis of such offsetting 
positions which is equal to the loss de-
scribed in clause (ii), and’’. 
(2)(A) Subparagraph (B) of section 1092(a)(2) 
is amended by adding at the end the following flush 
sentence: 
‘‘A straddle shall be treated as clearly identified 
for purposes of clause (i) only if such identifica-
tion includes an identification of the positions 
in the straddle which are offsetting with respect 
other positions in the straddle.’’. 
(B) Subparagraph (A) of section 1092(a)(2) is 
amended— 
(i) by striking ‘‘identified positions’’ in 
clause (i) and inserting ‘‘positions’’, 
(ii) by striking ‘‘identified position’’ in 
clause (ii) and inserting ‘‘position’’, and 
(iii) by striking ‘‘identified offsetting posi-
tions’’ in clause (ii) and inserting ‘‘offsetting 
positions’’. 
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(C) Subparagraph (B) of section 1092(a)(3) is 
amended by striking ‘‘identified offsetting position’’ 
and inserting ‘‘offsetting position’’. 
(3) Paragraph (2) of section 1092(a) is amend-
ed by redesignating subparagraph (C) as subpara-
graph (D) and inserting after subparagraph (B) the 
following new subparagraph: 
‘‘(C) APPLICATION
TO
LIABILITIES
AND 
OBLIGATIONS.—Except as otherwise provided 
by the Secretary, rules similar to the rules of 
clauses (ii) and (iii) of subparagraph (A) shall 
apply for purposes of this paragraph with re-
spect to any position which is, or has been, a 
liability or obligation.’’. 
(4) Subparagraph (D) of section 1092(a)(2), as 
redesignated by paragraph (3), is amended by in-
serting ‘‘the rules for the application of this section 
to a position which is or has been a liability or obli-
gation, methods of loss allocation which satisfy the 
requirements of subparagraph (A)(iii),’’ before ‘‘and 
the ordering rules’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall take effect as if included in the provisions 
of the American Jobs Creation Act of 2004 to which they 
relate. 
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SEC. 7. AMENDMENT RELATED TO THE JOBS AND GROWTH 
TAX RELIEF RECONCILIATION ACT OF 2003. 
(a) AMENDMENT RELATED TO SECTION 302 OF THE 
ACT.—Clause (ii) of section 1(h)(11)(B) is amended by 
striking ‘‘and’’ at the end of subclause (II), by striking 
the period at the end of subclause (III) and inserting ‘‘, 
and’’, and by adding at the end the following new sub-
clause: 
‘‘(IV) any dividend received from 
a corporation which is a DISC or 
former DISC (as defined in section 
992(a)) to the extent such dividend is 
paid out of the corporation’s accumu-
lated DISC income or is a deemed 
distribution 
pursuant 
to 
section 
995(b)(1).’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to dividends received on or after 
September 29, 2006, in taxable years ending after such 
date. 
SEC. 
8. 
AMENDMENTS 
RELATED 
TO 
THE 
ECONOMIC 
GROWTH AND TAX RELIEF RECONCILIATION 
ACT OF 2001. 
(a) AMENDMENTS RELATED TO SECTION 617 OF 
THE ACT.— 
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(1) Subclause (II) of section 402(g)(7)(A)(ii) is 
amended by striking ‘‘for prior taxable years’’ and 
inserting ‘‘permitted for prior taxable years by rea-
son of this paragraph’’. 
(2) Subparagraph (A) of section 3121(v)(1) is 
amended by inserting ‘‘or consisting of designated 
Roth contributions (as defined in section 402A(c))’’ 
before the comma at the end. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall take effect as if included in the provisions 
of the Economic Growth and Tax Relief Reconciliation Act 
of 2001 to which they relate. 
SEC. 9. AMENDMENT RELATED TO THE TAX RELIEF EXTEN-
SION ACT OF 1999. 
(a) AMENDMENT RELATED TO SECTION 507 OF THE 
ACT.—Clause (i) of section 45(e)(7)(A) is amended by 
striking ‘‘placed in service by the taxpayer’’ and inserting 
‘‘originally placed in service’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall take effect as if included in section 507 
of the Tax Relief Extension Act of 1999. 
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SEC. 10. AMENDMENT RELATED TO THE INTERNAL REV-
ENUE SERVICE RESTRUCTURING AND RE-
FORM ACT OF 1998. 
(a) AMENDMENT RELATED TO SECTION 3509 OF 
THE ACT.—Paragraph (3) of section 6110(i) is amended 
by inserting ‘‘and related background file documents’’ 
after ‘‘Chief Counsel advice’’ in the matter preceding sub-
paragraph (A). 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall take effect as if included in the provision 
of the Internal Revenue Service Restructuring and Reform 
Act of 1998 to which it relates. 
SEC. 11. CLERICAL CORRECTIONS. 
(a) IN GENERAL.— 
(1) Paragraph (5) of section 21(e) is amended 
by striking ‘‘section 152(e)(3)(A)’’ in the flush mat-
ter after subparagraph (B) and inserting ‘‘section 
152(e)(4)(A)’’. 
(2) Paragraph (3) of section 25C(c) is amended 
by striking ‘‘section 3280’’ and inserting ‘‘part 
3280’’. 
(3) Subsection (a) of section 34 is amended— 
(A) in paragraph (1), by striking ‘‘with re-
spect to gasoline used during the taxable year 
on a farm for farming purposes’’, 
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(B) in paragraph (2), by striking ‘‘with re-
spect to gasoline used during the taxable year 
(A) otherwise than as a fuel in a highway vehi-
cle or (B) in vehicles while engaged in fur-
nishing certain public passenger land transpor-
tation service’’, and 
(C) in paragraph (3), by striking ‘‘with re-
spect to fuels used for nontaxable purposes or 
resold during the taxable year’’. 
(4) Paragraph (2) of section 35(d) is amend-
ed— 
(A) by striking ‘‘paragraph (2) or (4) of’’, 
and 
(B) by striking ‘‘(within the meaning of 
section 152(e)(1))’’ and inserting ‘‘(as defined 
in section 152(e)(4)(A))’’. 
(5) Paragraph (24) of section 38(b) is amended 
by striking ‘‘and’’ at the end. 
(6) Paragraphs (2) and (3) of section 45L(c) 
are each amended by striking ‘‘section 3280’’ and 
inserting ‘‘part 3280’’. 
(7) Clause (ii) of section 48A(d)(4)(B) is 
amended by striking ‘‘subsection’’ both places it ap-
pears. 
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(8) The last sentence of section 125(b)(2) is 
amended by striking ‘‘last sentence’’ and inserting 
‘‘second sentence’’. 
(9) Subclause (II) of section 167(g)(8)(C)(ii) is 
amended by striking ‘‘section 263A(j)(2)’’ and in-
serting ‘‘section 263A(i)(2)’’. 
(10) Subparagraph (G) of section 1260(c)(2) is 
amended by adding ‘‘and’’ at the end. 
(11) Paragraph (2) of section 1297(a) is 
amended by striking ‘‘subsection (e)’’ and inserting 
‘‘subsection (f)’’. 
(12) Paragraph (2) of section 1400O is amend-
ed by striking ‘‘under of’’ and inserting ‘‘under’’. 
(13) The table of sections for part II of sub-
chapter Y of chapter 1 is amended by adding at the 
end the following new item: 
‘‘Sec. 1400T. Special rules for mortgage revenue bonds.’’. 
(14) Subsection (b) of section 4082 is amended 
to read as follows: 
‘‘(b) NONTAXABLE USE.—For purposes of this sec-
tion, the term ‘nontaxable use’ means— 
‘‘(1) any use which is exempt from the tax im-
posed by section 4041(a)(1) other than by reason of 
a prior imposition of tax, 
‘‘(2) any use in a train, and 
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‘‘(3) 
any 
use 
described 
in 
section 
4041(a)(1)(C)(iii)(II). 
The term ‘nontaxable use’ does not include the use of ker-
osene in an aircraft and such term shall not include any 
use described in section 6421(e)(2)(C).’’. 
(15) Paragraph (4) of section 4101(a) (relating 
to registration in event of change of ownership) is 
redesignated as paragraph (5). 
(16) Paragraph (6) of section 4965(c) is 
amended by striking ‘‘section 4457(e)(1)(A)’’ and 
inserting ‘‘section 457(e)(1)(A)’’. 
(17) Subpart C of part II of subchapter A of 
chapter 51 is amended by redesignating section 
5432 (relating to recordkeeping by wholesale deal-
ers) as section 5121. 
(18) Paragraph (2) of section 5732(c), as re-
designated by section 11125(b)(20)(A) of the 
SAFETEA–LU, is amended by striking ‘‘this sub-
part’’ and inserting ‘‘this subchapter’’. 
(19) Paragraph (3) of section 6427(e) (relating 
to termination), as added by section 11113 of the 
SAFETEA–LU, is redesignated as paragraph (5) 
and moved after paragraph (4). 
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(20) Clause (ii) of section 6427(l)(4)(A) is 
amended by striking ‘‘section 4081(a)(2)(iii)’’ and 
inserting ‘‘section 4081(a)(2)(A)(iii)’’. 
(21)(A) Section 6427, as amended by section 
1343(b)(1) of the Energy Policy Act of 2005, is 
amended by striking subsection (p) and redesig-
nating subsection (q) as subsection (p). 
(B) The Internal Revenue Code of 1986 shall 
be applied and administered as if the amendments 
made by paragraph (2) of section 11151(a) of the 
SAFETEA–LU had never been enacted. 
(22)(A) Paragraph (3) of section 9002 is 
amended by striking ‘‘section 309(a)(1)’’ and insert-
ing ‘‘section 306(a)(1)’’. 
(B) Paragraph (1) of section 9004(a) is amend-
ed by striking ‘‘section 320(b)(1)(B)’’ and inserting 
‘‘section 315(b)(1)(B)’’. 
(C) Paragraph (3) of section 9032 is amended 
by striking ‘‘section 309(a)(1)’’ and inserting ‘‘sec-
tion 306(a)(1)’’. 
(D) Subsection (b) of section 9034 is amended 
by striking ‘‘section 320(b)(1)(A)’’ and inserting 
‘‘section 315(b)(1)(A)’’. 
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(23) Section 9006 is amended by striking 
‘‘Comptroller General’’ each place it appears and in-
serting ‘‘Commission’’. 
(24) Subsection (c) of section 9503 is amended 
by redesignating paragraph (7) (relating to transfers 
from the trust fund for certain aviation fuels taxes) 
as paragraph (6). 
(25) Paragraph (1) of section 1301(g) of the 
Energy Policy Act of 2005 is amended by striking 
‘‘shall take effect of the date of the enactment’’ and 
inserting ‘‘shall take effect on the date of the enact-
ment’’. 
(b) CLERICAL AMENDMENTS RELATED
TO
THE 
GULF OPPORTUNITY ZONE ACT OF 2005.— 
(1) AMENDMENTS RELATED TO SECTION 402 OF 
THE ACT.—Subparagraph (B) of section 24(d)(1) is 
amended— 
(A) by striking ‘‘the excess (if any) of’’ in 
the matter preceding clause (i) and inserting 
‘‘the greater of’’, and 
(B) by striking ‘‘section’’ in clause (ii)(II) 
and inserting ‘‘section 32’’. 
(2) EFFECTIVE DATE.—The amendments made 
by this subsection shall take effect as if included in 
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the provisions of the Gulf Opportunity Zone Act of 
2005 to which they relate. 
(c) CLERICAL
AMENDMENTS
RELATED
TO
THE 
SAFE, ACCOUNTABLE, FLEXIBLE, EFFICIENT TRANSPOR-
TATION EQUITY ACT: A LEGACY FOR USERS.— 
(1) AMENDMENTS RELATED TO SECTION 11163 
OF
THE
ACT.—Subparagraph 
(C) 
of 
section 
6416(a)(4) is amended— 
(A) by striking ‘‘ultimate vendor’’ and all 
that follows through ‘‘has certified’’ and insert-
ing ‘‘ultimate vendor or credit card issuer has 
certified’’, and 
(B) by striking ‘‘all ultimate purchasers of 
the vendor’’ and all that follows through ‘‘are 
certified’’ and inserting ‘‘all ultimate purchasers 
of the vendor or credit card issuer are cer-
tified’’. 
(2) EFFECTIVE DATE.—The amendments made 
by this subsection shall take effect as if included in 
the provisions of the Safe, Accountable, Flexible, Ef-
ficient Transportation Equity Act: A Legacy for 
Users to which they relate. 
(d) CLERICAL AMENDMENTS RELATED TO THE EN-
ERGY POLICY ACT OF 2005.— 
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(1) AMENDMENT RELATED TO SECTION 1344 OF 
THE ACT.—Subparagraph (B) of section 6427(e)(5), 
as redesignated by subsection (a)(19), is amended by 
striking ‘‘2006’’ and inserting ‘‘2008’’. 
(2) AMENDMENTS RELATED TO SECTION 1351 
OF THE ACT.—Subparagraphs (A)(ii) and (B)(ii) of 
section 41(f)(1) are each amended by striking 
‘‘qualified research expenses and basic research pay-
ments’’ and inserting ‘‘qualified research expenses, 
basic research payments, and amounts paid or in-
curred to energy research consortiums,’’. 
(3) EFFECTIVE DATE.—The amendments made 
by this subsection shall take effect as if included in 
the provisions of the Energy Policy Act of 2005 to 
which they relate. 
Æ 
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