I 
119TH CONGRESS 
1ST SESSION H. R. 1083 
To amend the Internal Revenue Code of 1986 to exclude from gross income 
gain from the sale of qualified real property interests acquired under 
the authority of the Readiness and Environmental Protection Integration 
(REPI) program administered by the Department of Defense pursuant 
to section 2684a of title 10, United States Code, and for other purposes. 
IN THE HOUSE OF REPRESENTATIVES 
FEBRUARY 6, 2025 
Mr. MURPHY (for himself and Mr. PANETTA) introduced the following bill; 
which was referred to the Committee on Ways and Means 
A BILL 
To amend the Internal Revenue Code of 1986 to exclude 
from gross income gain from the sale of qualified real 
property interests acquired under the authority of the 
Readiness and Environmental Protection Integration 
(REPI) program administered by the Department of De-
fense pursuant to section 2684a of title 10, United 
States Code, and for other purposes. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
VerDate Sep 11 2014 
06:26 Mar 05, 2025
Jkt 059200
PO 00000
Frm 00001
Fmt 6652
Sfmt 6201
E:\BILLS\H1083.IH
H1083
kjohnson on DSK7ZCZBW3PROD with $$_JOB
SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘Incentivizing Readi-
ness and Environmental Protection Integration Sales Act 
of 2025’’. 
SEC. 2. EXCLUSION OF GAIN FROM SALE OF QUALIFIED 
REAL PROPERTY INTERESTS ACQUIRED FOR 
PURPOSES RELATED TO THE READINESS AND 
ENVIRONMENTAL 
PROTECTION 
INTEGRA-
TION PROGRAM. 
(a) IN GENERAL.—Part III of subchapter B of chap-
ter 1 of the Internal Revenue Code of 1986 is amended 
by inserting after section 139I the following new section: 
‘‘SEC. 139J. GAIN FROM SALE OF QUALIFIED REAL PROP-
ERTY INTEREST FOR PURPOSES RELATED TO 
THE READINESS AND ENVIRONMENTAL PRO-
TECTION INTEGRATION PROGRAM. 
‘‘(a) IN GENERAL.—Gross income shall not include 
any gain from the sale of qualified real property interest 
to a qualified organization for REPI purposes. 
‘‘(b) DEFINITIONS.—For purposes of this section— 
‘‘(1) QUALIFIED REAL PROPERTY INTEREST.— 
‘‘(A) IN
GENERAL.—The term ‘qualified 
real property interest’ means any of the fol-
lowing interests in real property: 
‘‘(i) The entire interest of the tax-
payer. 
VerDate Sep 11 2014 
06:26 Mar 05, 2025
Jkt 059200
PO 00000
Frm 00002
Fmt 6652
Sfmt 6201
E:\BILLS\H1083.IH
H1083
kjohnson on DSK7ZCZBW3PROD with $$_JOB
‘‘(ii) A remainder interest. 
‘‘(iii) A restriction (granted in per-
petuity and created pursuant to State real 
property law) on the use which may be 
made of the real property. 
‘‘(B) SPECIAL RULE FOR MINERAL INTER-
ESTS.—An interest in real property shall not 
fail to be treated as a qualified real property in-
terest solely by reason of a retention of a quali-
fied mineral interest (as defined in section 
170(h)(6)), but only if the right to access such 
mineral interest is not accomplished by any sur-
face mining method. 
‘‘(2) QUALIFIED
ORGANIZATION.—The term 
‘qualified organization’ has the meaning given such 
term by section 170(h)(3). 
‘‘(3) REPI PURPOSES.—A sale of qualified real 
property interest shall be treated as being for REPI 
purposes if such sale is pursuant to the authority of 
the Readiness and Environmental Protection Inte-
gration (REPI) program administered by the De-
partment of Defense under section 2684a of title 10, 
United States Code. 
‘‘(c) LIMITATION.— 
VerDate Sep 11 2014 
06:26 Mar 05, 2025
Jkt 059200
PO 00000
Frm 00003
Fmt 6652
Sfmt 6201
E:\BILLS\H1083.IH
H1083
kjohnson on DSK7ZCZBW3PROD with $$_JOB
‘‘(1) IN
GENERAL.—In the case of a pass- 
through entity, no amount shall be excluded from 
gross income under subsection (a) with respect to a 
sale if such entity acquired the qualified real prop-
erty interest by sale within 3 years of the date of the 
sale described in subsection (a). 
‘‘(2) EXCEPTION FOR FAMILY PARTNERSHIPS 
OR FAMILY PASS-THROUGH ENTITIES.— 
‘‘(A) IN
GENERAL.—Paragraph (1) shall 
not apply with respect to any sale made by any 
partnership if substantially all of the partner-
ship interests in such partnership are held, di-
rectly or indirectly, by an individual and mem-
bers of the family of such individual. 
‘‘(B) MEMBERS
OF
THE
FAMILY.—For 
purposes of this paragraph, the term ‘members 
of the family’ means, with respect to any indi-
vidual— 
‘‘(i) the spouse of such individual, and 
‘‘(ii) any individual who bears a rela-
tionship to such individual which is de-
scribed in subparagraphs (A) through (G) 
of section 152(d)(2). 
‘‘(C) 
APPLICATION
TO
OTHER
PASS- 
THROUGH ENTITIES.—Except as may be other-
VerDate Sep 11 2014 
06:26 Mar 05, 2025
Jkt 059200
PO 00000
Frm 00004
Fmt 6652
Sfmt 6201
E:\BILLS\H1083.IH
H1083
kjohnson on DSK7ZCZBW3PROD with $$_JOB
wise provided by the Secretary, the rules of this 
paragraph shall apply to S corporations and 
other pass-through entities in the same manner 
as such rules apply to partnerships.’’. 
(b) CLERICAL AMENDMENT.—The table of sections 
for part III of subchapter B of chapter 1 of the Internal 
Revenue Code of 1986 is amended by inserting after the 
item relating to section 139I the following new item: 
‘‘Sec. 139J. Gain from sale of qualified real property interest for purposes re-
lated to the readiness and environmental protection integration 
program.’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning after 
the date of the enactment of this Act. 
Æ 
VerDate Sep 11 2014 
06:26 Mar 05, 2025
Jkt 059200
PO 00000
Frm 00005
Fmt 6652
Sfmt 6301
E:\BILLS\H1083.IH
H1083
kjohnson on DSK7ZCZBW3PROD with $$_JOB