datamatters24/research-document-archive huggingface dataset:
106 
amended by striking ‘‘115 percent’’ and inserting ‘‘181 
percent’’. 
Passed the House of Representatives November 9, 
2007. 
Attest: 
Clerk.
110TH CONGRESS 
1ST SESSION 
H. R. 3996 
AN ACT 
To amend the Internal Revenue Code of 1986 to 
extend certain expiring provisions, and for other 
purposes.
991 
210), as amended, in such amounts and at such times as 
may be necessary to pay any amounts required pursuant 
to the guarantee of the principal amount of obligations 
under sections 511 through 513 of such Act, such author-
ity to exist as long as any such guaranteed obligation is 
outstanding: Provided, That pursuant to section 502 of 
such Act, as amended, no new direct loans or loan guar-
antee commitments shall be made using Federal funds for 
the credit risk premium during fiscal year 2009. 
RAIL LINE RELOCATION AND IMPROVEMENT PROGRAM 
For necessary expenses of carrying out section 20154 
of title 49, United States Code, as authorized by section 
9002 of Public Law 109–59, $25,000,000, to remain 
available until expended. 
OPERATING GRANTS TO THE NATIONAL RAILROAD 
PASSENGER CORPORATION 
To enable the Secretary of Transportation to make 
quarterly grants to the National Railroad Passenger Cor-
poration for operation of intercity passenger rail, 
$550,000,000, to remain available until expended: Pro-
vided, That the Secretary shall withhold such sums as 
shall be necessary for the costs associated with the second 
retroactive wage payment to Amtrak employees and shall 
transmit such funding to the corporation for the sole and 
exclusive purpose of making such payments only at such 
time as said payments are due: Provided further, That 
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992 
such remaining amounts available under this paragraph 
shall be available for the Secretary to approve funding to 
cover operating losses for the Corporation only after re-
ceiving and reviewing a grant request for each specific 
train route: Provided further, That each such grant re-
quest shall be accompanied by a detailed financial anal-
ysis, revenue projection, and capital expenditure projection 
justifying the Federal support to the Secretary’s satisfac-
tion: Provided further, That the Corporation is directed 
to achieve savings through operating efficiencies including, 
but not limited to, modifications to food and beverage 
service and first class service: Provided further, That the 
Inspector General of the Department of Transportation 
shall report to the House and Senate Committees on Ap-
propriations beginning 3 months after the date of the en-
actment of this Act and quarterly thereafter with esti-
mates of the savings accrued as a result of all operational 
reforms instituted by the Corporation: Provided further, 
That not later than 120 days after enactment of this Act, 
the Corporation shall transmit to the House and Senate 
Committees on Appropriations the status of its plan to 
improve the financial performance of food and beverage 
service and its plan to improve the financial performance 
of first class service (including sleeping car service): Pro-
vided further, That the Corporation shall report quarterly 
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I 
111TH CONGRESS 
1ST SESSION 
H. R. 127 
To amend the Immigration and Nationality Act to change certain 
requirements relating to a sponsor’s affidavit of support for an alien. 
IN THE HOUSE OF REPRESENTATIVES 
JANUARY 6, 2009 
Mr. GALLEGLY introduced the following bill; which was referred to the 
Committee on the Judiciary 
A BILL 
To amend the Immigration and Nationality Act to change 
certain requirements relating to a sponsor’s affidavit of 
support for an alien. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. REQUIREMENTS FOR SPONSOR’S AFFIDAVIT OF 
SUPPORT. 
(a) MAINTENANCE
OF ANNUAL INCOME.—Section 
213A(a)(1)(A) of the Immigration and Nationality Act (8 
U.S.C. 1183a(a)(1)(A)) is amended by striking ‘‘125 per-
cent of the Federal poverty line’’ and inserting ‘‘300 per-
cent of the Federal poverty line (or in cases where the 
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HR 3996 PCS
(i) by striking ‘‘section 6662(h)’’ and 
inserting ‘‘subsection (h) or (i) of section 
6662’’, and 
(ii) by striking ‘‘GROSS
VALUATION 
MISSTATEMENT PENALTY’’ in the heading 
and inserting ‘‘CERTAIN
INCREASED
UN-
DERPAYMENT PENALTIES’’. 
(3) REASONABLE CAUSE EXCEPTION NOT AP-
PLICABLE.—Subsection (c) of section 6664 is 
amended— 
(A) by redesignating paragraphs (2) and 
(3) as paragraphs (3) and (4), respectively, 
(B) by striking ‘‘paragraph (2)’’ in para-
graph (4), as so redesignated, and inserting 
‘‘paragraph (3)’’, and 
(C) by inserting after paragraph (1) the 
following new paragraph: 
‘‘(2) EXCEPTION.—Paragraph (1) shall not 
apply to any portion of an underpayment to which 
this section applies by reason of subsection (b)(6).’’. 
(d) CONFORMING AMENDMENTS.— 
(1) Subsection (d) of section 731 is amended by 
inserting ‘‘section 710(b)(4) (relating to distribu-
tions of partnership property),’’ before ‘‘section 
736’’. 
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HR 127 IH 
sponsored alien is the spouse or a child of the sponsor, 
not less than 200 percent of the Federal poverty line)’’. 
(b) SPONSOR DEFINED.— 
(1) IN GENERAL.—Section 213A(f)(1)(E) of the 
Immigration 
and 
Nationality 
Act 
(8 
U.S.C. 
1183a(f)(1)(E)) is amended by striking ‘‘125 per-
cent of the Federal poverty line’’ and inserting ‘‘300 
percent of the Federal poverty line (or in cases 
where the sponsored alien is the spouse or a child 
of the individual, at least 200 percent of the Federal 
poverty line)’’. 
(2) CERTAIN EMPLOYMENT-BASED IMMIGRANTS 
CASES.—Section 213A(f)(4)(B)(i) of the Immigra-
tion 
and 
Nationality 
Act 
(8 
U.S.C. 
1183a(f)(4)(B)(i)) is amended by striking ‘‘125 per-
cent of the Federal poverty line’’ and inserting ‘‘300 
percent of the Federal poverty line (or in cases 
where the sponsored alien is the spouse or a child 
of the individual, at least 200 percent of the Federal 
poverty line)’’. 
(3) 
NON-PETITIONING
CASES.—Section 
213A(f)(5)(A) of the Immigration and Nationality 
Act (8 U.S.C. 1183a(f)(5)(A)) is amended by strik-
ing ‘‘125 percent of the Federal poverty line’’ and 
inserting ‘‘300 percent of the Federal poverty line 
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(2) Section 741 is amended by inserting ‘‘or 
section 710 (relating to special rules for partners 
providing investment management services to part-
nership)’’ before the period at the end. 
(3) Paragraph (13) of section 1402(a) is 
amended— 
(A) by striking ‘‘other than guaranteed’’ 
and inserting ‘‘other than— 
‘‘(A) guaranteed’’, 
(B) by striking the semi-colon at the end 
and inserting ‘‘, and’’, and 
(C) by adding at the end the following new 
subparagraph: 
‘‘(B) any income treated as ordinary in-
come under section 710 received by an indi-
vidual who provides investment management 
services (as defined in section 710(d)(2));’’. 
(4) Paragraph (12) of section 211(a) of the So-
cial Security Act is amended— 
(A) by striking ‘‘other than guaranteed’’ 
and inserting ‘‘other than— 
‘‘(A) guaranteed’’, 
(B) by striking the semi-colon at the end 
and inserting ‘‘, and’’, and 
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102 
HR 3996 PCS
Secretary determines necessary to carry out the purposes 
of this section— 
‘‘(1) the name, address, phone number, and 
email address of the information contact of such 
person, and 
‘‘(2) the information described in paragraphs 
(1), (2), and (3) of subsection (a).’’. 
(2) ASSESSABLE PENALTIES.— 
(A) 
Subparagraph 
(B) 
of 
section 
6724(d)(1) of such Code (defining information 
return) is amended by redesignating clauses (iv) 
through (xix) as clauses (v) through (xx), re-
spectively, and by inserting after clause (iii) the 
following new clause: 
‘‘(iv) section 6045B(a) (relating to re-
turns relating to actions affecting basis of 
specified securities),’’. 
(B) Paragraph (2) of section 6724(d) of 
such Code (defining payee statement), as 
amended by subsection (c)(2), is amended by 
redesignating subparagraphs (J) through (DD) 
as subparagraphs (K) through (EE), respec-
tively, and by inserting after subparagraph (I) 
the following new subparagraph: 
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(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to taxable years beginning after 
December 31, 2007. 
SEC. 323. NEW MARKETS TAX CREDIT. 
Subparagraph (D) of section 45D(f)(1) (relating to 
national limitation on amount of investments designated) 
is amended by striking ‘‘and 2008’’ and inserting ‘‘2008, 
and 2009’’. 
SEC. 324. RAILROAD TRACK MAINTENANCE. 
(a) IN GENERAL.—Subsection (f) of section 45G (re-
lating to application of section) is amended by striking 
‘‘January 1, 2008’’ and inserting ‘‘January 1, 2009’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to expenditures paid or incurred 
during taxable years beginning after December 31, 2007. 
SEC. 325. FIFTEEN-YEAR STRAIGHT-LINE COST RECOVERY 
FOR QUALIFIED LEASEHOLD IMPROVEMENTS 
AND QUALIFIED RESTAURANT PROPERTY. 
(a) IN GENERAL.—Clauses (iv) and (v) of section 
168(e)(3)(E) (relating to 15-year property) are each 
amended by striking ‘‘January 1, 2008’’ and inserting 
‘‘January 1, 2009’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to property placed in service after 
December 31, 2007. 
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$5,000,000.—Paragraph (1) of section 6721(d) is amend-
ed— 
(1) by striking ‘‘$100,000’’ in subparagraph 
(A) and inserting ‘‘$250,000’’, 
(2) by striking ‘‘$25,000’’ in subparagraph (B) 
and inserting ‘‘$75,000’’, and 
(3) by striking ‘‘$50,000’’ in subparagraph (C) 
and inserting ‘‘$150,000’’. 
(e) PENALTY
IN
CASE
OF
INTENTIONAL
DIS-
REGARD.—Paragraph (2) of section 6721(e) is amended 
by striking ‘‘$100’’ and inserting ‘‘$250’’. 
(f) FAILURE TO FURNISH CORRECT PAYEE STATE-
MENTS.— 
(1) IN
GENERAL.—Subsection (a) of section 
6722 is amended by striking ‘‘$50’’ and inserting 
‘‘$100’’. 
(2) AGGREGATE
ANNUAL
LIMITATION.—Sub-
sections (a) and (c)(2)(A) of section 6722 are each 
amended by striking ‘‘$100,000’’ and inserting 
‘‘$600,000’’. 
(3) PENALTY IN CASE OF INTENTIONAL DIS-
REGARD.—Paragraph (1) of section 6722(c) is 
amended by striking ‘‘$100’’ and inserting ‘‘$250’’. 
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(g) FAILURE TO COMPLY WITH OTHER INFORMA-
TION
REPORTING
REQUIREMENTS.—Section 6723 is 
amended— 
(1) by striking ‘‘$50’’ and inserting ‘‘$100’’, 
and 
(2) by striking ‘‘$100,000’’ and inserting 
‘‘$600,000’’. 
(h) EFFECTIVE DATE.—The amendments made by 
this section shall apply with respect to information returns 
required to be filed on or after January 1, 2008. 
SEC. 407. UNUSED MERCHANDISE DRAWBACK. 
(a) IN GENERAL.—Section 313(j)(2) of the Tariff 
Act of 1930 (19 U.S.C. 1313(j)(2)) is amended by adding 
at the end the following: ‘‘For purposes of subparagraph 
(A) of this paragraph, wine of the same color shall be 
deemed to be commercially interchangeable.’’. 
(b) EFFECTIVE DATE.—The amendment made by 
subsection (a) shall take effect on the date of the enact-
ment of this Act. 
Æ 
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108TH CONGRESS
2D SESSION
H. R. 3818
AN ACT
To amend the Foreign Assistance Act of 1961 to
improve the results and accountability of micro-
enterprise development assistance programs, and
for other purposes.
108TH CONGRESS
2D SESSION
H. R. 3818
AN ACT
To amend the Foreign Assistance Act of 1961 to improve
the results and accountability of microenterprise develop-
ment assistance programs, and for other purposes.
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled,
108TH CONGRESS
2D SESSION
H. R. 3819
AN ACT
To redesignate Fort Clatsop National Memorial as
the Lewis and Clark National Historical Park, to
include in the park sites in the State of Wash-
ington as well as the State of Oregon, and for
other purposes.
108TH CONGRESS
2D SESSION
H. R. 3846
AN ACT
To authorize the Secretary of Agriculture and the
Secretary of the Interior to enter into an agree-
ment or contract with Indian tribes meeting cer-
tain criteria to carry out projects to protect In-
dian forest land.
108TH CONGRESS
2D SESSION
H. R. 3850
AN ACT
To provide an extension of highway, highway safety, motor
carrier safety, transit, and other programs funded out
of the Highway Trust Fund pending enactment of a
law reauthorizing the Transportation Equity Act for the
21st Century.
108TH CONGRESS
2D SESSION
H. R. 3858
AN ACT
To amend the Public Health Service Act to increase
the supply of pancreatic islet cells for research,
and to provide for better coordination of Federal
efforts and information on islet cell transplan-
tation.
†
HR 3997 EAS2
SEC. 310. 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 in-
serting ‘‘and related background file documents’’ after
‘‘Chief Counsel advice’’ in the matter preceding subpara-
graph (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. 311. CLERICAL CORRECTIONS.
(a) IN GENERAL.—
(1) Paragraph (5) of section 21(e) is amended by
striking ‘‘section 152(e)(3)(A)’’ in the flush matter
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) Paragraph (2) of section 26(b) is amended by
redesignating subparagraphs (S) and (T) as subpara-
graphs (U) and (V), respectively, and by inserting
after subparagraph (R) the following new subpara-
graphs:
†
HR 3997 EAS2
‘‘(S) 
sections 
106(e)(3)(A)(ii),
223(b)(8)(B)(i)(II), and 408(d)(9)(D)(i)(II) (re-
lating to certain failures to maintain high de-
ductible health plan coverage),
‘‘(T) section 170(o)(3)(B) (relating to recap-
ture of certain deductions for fractional gifts),’’.
(4) 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’’,
(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 vehicle
or (B) in vehicles while engaged in furnishing
certain public passenger land transportation
service’’, and
(C) in paragraph (3), by striking ‘‘with re-
spect to fuels used for nontaxable purposes or re-
sold during the taxable year’’.
(5) Paragraph (2) of section 35(d) is amended—
(A) by striking ‘‘paragraph (2) or (4) of’’,
and
(B) by striking ‘‘(within the meaning of sec-
tion 152(e)(1))’’ and inserting ‘‘(as defined in
section 152(e)(4)(A))’’.
108TH CONGRESS
2D SESSION
H. R. 3866
AN ACT
To amend the Controlled Substances Act to provide increased
penalties for anabolic steroid offenses near sports facili-
ties, and for other purposes.
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled,
I 
108TH CONGRESS 
2D SESSION 
H. R. 3870
To amend the Public Health Service Act, the Federal Food, Drug, and 
Cosmetic Act, and the Controlled Substances Import and Export Act 
to provide grants to States to establish prescription drug monitoring 
programs, to impose requirements respecting Internet pharmacies, to 
require manufacturers to implement chain-of-custody procedures, to re-
strict an exemption respecting the importation of controlled substances 
for personal use, and for other purposes. 
IN THE HOUSE OF REPRESENTATIVES 
MARCH 2, 2004
Mr. NORWOOD (for himself and Mr. STRICKLAND) introduced the following 
bill; which was referred to the Committee on Energy and Commerce 
A BILL 
To amend the Public Health Service Act, the Federal Food, 
Drug, and Cosmetic Act, and the Controlled Substances 
Import and Export Act to provide grants to States to 
establish prescription drug monitoring programs, to im-
pose requirements respecting Internet pharmacies, to re-
quire manufacturers to implement chain-of-custody pro-
cedures, to restrict an exemption respecting the importa-
tion of controlled substances for personal use, and for 
other purposes.
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled,
†
HR 3997 EAS
‘‘(8) SPECIAL RULES WHEN UNIFORMED SERV-
ICES RETIRED PAY IS REDUCED AS A RESULT OF
AWARD OF DISABILITY COMPENSATION.—
‘‘(A) PERIOD
OF
LIMITATION
ON
FILING
CLAIM.—If the claim for credit or refund relates
to an overpayment of tax imposed by subtitle A
on account of—
‘‘(i) the reduction of uniformed services
retired pay computed under section 1406 or
1407 of title 10, United States Code, or
‘‘(ii) the waiver of such pay under sec-
tion 5305 of title 38 of such Code,
as a result of an award of compensation under
title 38 of such Code pursuant to a determina-
tion by the Secretary of Veterans Affairs, the 3-
year period of limitation prescribed in subsection
(a) shall be extended, for purposes of permitting
a credit or refund based upon the amount of such
reduction or waiver, until the end of the 1-year
period beginning on the date of such determina-
tion.
‘‘(B) LIMITATION TO 5 TAXABLE YEARS.—
Subparagraph (A) shall not apply with respect
to any taxable year which began more than 5
years before the date of such determination.’’.
108TH CONGRESS
2D SESSION
H. R. 3884
AN ACT
To designate the Federal building and United
States courthouse located at 615 East Houston
Street in San Antonio, Texas, as the ‘‘Hipolito
F. Garcia Federal Building and United States
Courthouse’’.
112 
TITLE V—PARITY IN APPLICA-
TION OF CERTAIN LIMITS TO 
MENTAL HEALTH BENEFITS 
SEC. 501. PARITY IN APPLICATION OF CERTAIN LIMITS TO 
MENTAL HEALTH BENEFITS. 
(a) AMENDMENT TO THE INTERNAL REVENUE CODE 
OF 1986.—Section 9812(f)(3) of the Internal Revenue Code 
of 1986 is amended by striking ‘‘2007’’ and inserting 
‘‘2008’’. 
(b) AMENDMENT TO THE EMPLOYEE RETIREMENT IN-
COME SECURITY ACT OF 1974.—Section 712(f) of the Em-
ployee Retirement Income Security Act of 1974 (29 U.S.C. 
1185a(f)) is amended by striking ‘‘2007’’ and inserting 
‘‘2008’’. 
(c) AMENDMENT TO THE PUBLIC HEALTH SERVICE 
ACT.—Section 2705(f) of the Public Health Service Act (42 
U.S.C. 300gg-5(f)) is amended by striking ‘‘2007’’ and in-
serting ‘‘2008’’. 
(d) EFFECTIVE DATE.—The amendments made by this 
section shall apply to benefits for services furnished after 
December 31, 2007. 
Attest: 
Clerk.
110TH CONGRESS 
1ST SESSION 
H.R. 3997 
HOUSE AMENDMENT 
TO SENATE 
AMENDMENTS
†
100
HR 3997 EAS2
(A) by striking ‘‘, section 1361(b)(3)(B)(ii),
or section 1361(c)(1)(A)(ii)’’ and inserting ‘‘or
section 1361(b)(3)(B)(ii)’’, and
(B) by striking ‘‘, section 1361(b)(3)(C), or
section 1361(c)(1)(D)(iii)’’ in subparagraph (B)
and inserting ‘‘or section 1361(b)(3)(C)’’.
(25) Paragraph (2) of section 1400O is amended
by striking ‘‘under of’’ and inserting ‘‘under’’.
(26) 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.’’.
(27) Subsection (b) of section 4082 is amended
to read as follows:
‘‘(b) NONTAXABLE USE.—For purposes of this section,
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
‘‘(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).’’.
108TH CONGRESS
1ST SESSION
H. R. 389
AN ACT
To authorize the use of certain grant funds to es-
tablish an information clearinghouse that pro-
vides information to increase public access to
defibrillation in schools.
†
HR 3997 EAS2
uniformed services described in section
3401(h)(2)(A).
‘‘(ii) LIMITATION.—If an individual
elects to receive a distribution by reason of
clause (i), the plan shall provide that the
individual may not make an elective defer-
ral or employee contribution during the 6-
month period beginning on the date of the
distribution.
‘‘(C) NONDISCRIMINATION REQUIREMENT.—
Subparagraph (A)(iii) shall apply only if all
employees of an employer (as determined under
subsections (b), (c), (m), and (o)) performing
service in the uniformed services described in sec-
tion 3401(h)(2)(A) are entitled to receive dif-
ferential wage payments on reasonably equiva-
lent terms and, if eligible to participate in a re-
tirement plan maintained by the employer, to
make contributions based on the payments on
reasonably equivalent terms. For purposes of ap-
plying this subparagraph, the provisions of
paragraphs (3), (4), and (5) of section 410(b)
shall apply.
‘‘(D) DIFFERENTIAL WAGE PAYMENT.—For
purposes of this paragraph, the term ‘differential
amounts treated as a rollover by the subpara-
graph (A). 
‘‘(C) APPLICATION OF SECTION 72.—For 
purposes of applying section 72 in the case of 
a distribution which is includible in gross in-
come under paragraph (1), the amount treated 
as a rollover by reason of subparagraph (A) 
shall be treated as investment in the contract.’’. 
(d) EFFECTIVE DATES.— 
(1) IN GENERAL.—Except as provided by para-
graphs (2) and (3), the amendments made by this 
section shall apply with respect to deaths from inju-
ries occurring on or after the date of the enactment 
of this Act. 
(2) APPLICATION OF AMENDMENTS TO DEATHS 
FROM INJURIES OCCURRING ON OR AFTER OCTOBER 
7, 2001, AND
BEFORE
ENACTMENT.—The amend-
ments made by this section shall apply to any con-
tribution made pursuant to section 408A(e)(2) or 
530(d)(5) of the Internal Revenue Code of 1986, as 
amended by this Act, with respect to amounts re-
ceived under section 1477 of title 10, United States 
Code, or under section 1967 of title 38 of such 
Code, for deaths from injuries occurring on or after 
October 7, 2001, and before the date of the enact-
dividual made before the end of the 1-year pe-
riod beginning on the date on which such indi-
vidual receives an amount under section 1477 
of title 10, United States Code, or section 1967 
of title 38 of such Code, with respect to a per-
son, to the extent that such contribution does 
not exceed— 
‘‘(i) the sum of the amounts received 
during such period by such individual 
under such sections with respect to such 
person, reduced by 
‘‘(ii) the amounts so received which 
were contributed to a Coverdell education 
savings account under section 530(d)(9). 
‘‘(B) ANNUAL
LIMIT
ON
NUMBER
OF 
ROLLOVERS
NOT
TO
APPLY.—Section 
408(d)(3)(B) shall not apply with respect to 
amounts treated as a rollover by the subpara-
graph (A). 
‘‘(C) APPLICATION OF SECTION 72.—For 
purposes of applying section 72 in the case of 
a distribution which is not a qualified distribu-
tion, the amount treated as a rollover by reason 
of subparagraph (A) shall be treated as invest-
ment in the contract.’’.