(1) and within the applicable period prescribed in
section 1034, the taxpayer purchases a new principal
residence, then paragraph (1) shall not apply and
the tax imposed by this chapter for the taxable year
in which the new principal residence is purchased is
increased to the extent the amount of the credit that
could be claimed under this section on the purchase
of the new residence (were such residence purchased
during the eligibility period) is less than the amount
of credit claimed by the taxpayer under this section.
‘‘(3) DEATH OF OWNER; CASUALTY LOSS; IN-
VOLUNTARY
CONVERSION; 
ETC.—Paragraph (1)
shall not apply to—
‘‘(A) a disposition of a residence made on
account of the death of any individual having a
legal or equitable interest therein occurring dur-
ing the 36-month period referred to in para-
graph (1),
‘‘(B) a disposition of the old residence if it
is substantially or completely destroyed by a
casualty described in section 165(c)(3) or
compulsorily or involuntarily converted (within
the meaning of section 1033(a)), or
‘‘(C) a disposition pursuant to a settlement
in a divorce or legal separation proceeding
where the residence is sold or the other spouse
retains the residence as a principal residence.
‘‘(g) BASIS ADJUSTMENT.—For purposes of this sub-
title, if a credit is allowed under this section with respect
to the purchase of any residence, the basis of such resi-
dence shall be reduced by the amount of the credit so al-
lowed.’’.
(b) CONFORMING AMENDMENTS.—
(1) Subsection (a) of section 1016 of such Code
is amended by striking ‘‘and’’ at the end of para-
graph (24), by striking the period at the end of
paragraph (25) and inserting ‘‘, and’’, and by add-
ing at the end thereof the following new paragraph:
‘‘(26) in the case of a residence with respect to
which a credit was allowed under section 23, to the
extent provided in section 23(g).’’
(2) The table of sections for subpart A of part
IV of subchapter A of chapter 1 of such Code is
amended by inserting after the item relating to sec-
tion 22 the following new item:
‘‘Sec. 23. Purchase of principal residence by first-time home-
buyer.’’
(c) EFFECTIVE DATE.—The amendments made by
this section shall apply to taxable years ending after De-
cember 31, 1994.
Subtitle B—Revenue Increases
SEC. 3101. STOCK TRANSFER EXCISE TAX.
(a) IN GENERAL.—Chapter 34 of the Internal Reve-
nue Code of 1986 is amended by striking the chapter
heading and inserting the following:
‘‘CHAPTER 34—TAX ON CERTAIN
FINANCIAL TRANSACTIONS
‘‘Subchapter A. Tax on stock transfers.
‘‘Subchapter B. Policies issued by foreign insurers.
‘‘SUBCHAPTER A—TAX ON STOCK TRANSFERS
‘‘Sec. 4301. Imposition of tax.
‘‘Sec. 4302. Collection of tax.
‘‘Sec. 4303. Taxable stock transfer.
‘‘Sec. 4304. Taxable stock.
‘‘SEC. 4301. IMPOSITION OF TAX.
‘‘(a) IN GENERAL.—There is hereby imposed on each
taxable stock transfer a tax equal to 0.25 percent of the
amount realized by the transferor of the taxable stock.
‘‘(b) AMOUNT REALIZED.—For purposes of sub-
section (a)—
‘‘(1) IN GENERAL.—Except as otherwise pro-
vided in this subsection, the term ‘amount realized’
has the same meaning as when used in section 1001.
‘‘(2) TRANSFERS WHICH ARE NOT SALES OR
EXCHANGES.—In the case of any taxable stock
transfer which is not a sale or exchange, the amount