197
(A) IN GENERAL.—
(i) 
Subparagraph 
(B) 
of 
section
884(f)(1) is amended by striking ‘‘to the ex-
tent’’ and all that follows down through
‘‘subparagraph (A)’’ and inserting ‘‘to the
extent that the allocable interest exceeds the
interest described in subparagraph (A)’’.
(ii) The second sentence of section
884(f)(1) is amended by striking ‘‘reason-
ably expected’’ and all that follows down
through the period at the end thereof and
inserting ‘‘reasonably expected to be alloca-
ble interest.’’
(iii) Paragraph (2) of section 884(f) is
amended to read as follows:
‘‘(2) ALLOCABLE
INTEREST.—For purposes of
this subsection, the term ‘allocable interest’ means any
interest which is allocable to income which is effec-
tively connected (or treated as effectively connected)
with the conduct of a trade or business in the United
States.’’
(B) EFFECTIVE
DATE.—The amendments
made by subparagraph (A) shall take effect as if
included in the amendments made by section
1241(a) of the Tax Reform Act of 1986.
198
(4) CLARIFICATION OF SOURCE RULE.—
(A) IN GENERAL.—Paragraph (2) of section
865(b) is amended by striking ‘‘863(b)’’ and in-
serting ‘‘863’’.
(B) EFFECTIVE
DATE.—The amendment
made by subparagraph (A) shall take effect as if
included in the amendments made by section
1211 of the Tax Reform Act of 1986.
(5) REPEAL OF OBSOLETE PROVISIONS.—
(A) Paragraph (1) of section 6038(a) is
amended by striking ‘‘, and’’ at the end of sub-
paragraph (E) and inserting a period, and by
striking subparagraph (F).
(B) Subsection (b) of section 6038A is
amended by adding ‘‘and’’ at the end of para-
graph (2), by striking ‘‘, and’’ at the end of
paragraph (3) and inserting a period, and by
striking paragraph (4).
(g) TREATMENT
OF ASSIGNMENT
OF INTEREST
IN
CERTAIN BOND-FINANCED FACILITIES.—
(1) IN GENERAL.—Subparagraph (A) of section
1317(3) of the Tax Reform Act of 1986 is amended
by adding at the end thereof the following new sen-
tence: ‘‘A facility shall not fail to be treated as de-
scribed in this subparagraph by reason of an assign-
199
ment (or an agreement to an assignment) by the gov-
ernmental unit on whose behalf the bonds are issued
of any part of its interest in the property financed by
such bonds to another governmental unit.’’
(2) EFFECTIVE DATE.—The amendment made by
paragraph (1) shall take effect as if included in such
section 1317 on the date of the enactment of the Tax
Reform Act of 1986.
(h) CLARIFICATION OF TREATMENT OF MEDICARE EN-
TITLEMENT UNDER COBRA PROVISIONS.—
(1) IN GENERAL.—
(A) 
Subclause 
(V) 
of 
section
4980B(f)(2)(B)(i) is amended to read as follows:
‘‘(V) 
MEDICARE
ENTITLEMENT
FOLLOWED BY QUALIFYING EVENT.—In
the case of a qualifying event described
in paragraph (3)(B) that occurs less
than 18 months after the date the cov-
ered employee became entitled to bene-
fits under title XVIII of the Social Se-
curity Act, the period of coverage for
qualified beneficiaries other than the
covered employee shall not terminate
under this clause before the close of the
36-month period beginning on the date
200
the covered employee became so enti-
tled.’’
(B) Clause (v) of section 602(2)(A) of the
Employee Retirement Income Security Act of
1974 is amended to read as follows:
‘‘(v) MEDICARE
ENTITLEMENT
FOL-
LOWED BY QUALIFYING EVENT.—In the case
of a qualifying event described in section
603(2) that occurs less than 18 months after
the date the covered employee became enti-
tled to benefits under title XVIII of the So-
cial Security Act, the period of coverage for
qualified beneficiaries other than the covered
employee shall not terminate under this
subparagraph before the close of the 36-
month period beginning on the date the cov-
ered employee became so entitled.’’
(C) Clause (iv) of section 2202(2)(A) of the
Public Health Service Act is amended to read as
follows:
‘‘(iv) MEDICARE
ENTITLEMENT
FOL-
LOWED BY QUALIFYING EVENT.—In the case
of a qualifying event described in section
2203(2) that occurs less than 18 months
after the date the covered employee became
201
entitled to benefits under title XVIII of the
Social Security Act, the period of coverage
for qualified beneficiaries other than the
covered employee shall not terminate under
this subparagraph before the close of the 36-
month period beginning on the date the cov-
ered employee became so entitled.’’
(2) EFFECTIVE DATE.—The amendments made
by this subsection shall apply to plan years beginning
after December 31, 1989.
(i) TREATMENT OF CERTAIN REMIC INCLUSIONS.—
(1) IN GENERAL.—Subsection (a) of section 860E
is amended by adding at the end thereof the following
new paragraph:
‘‘(6) COORDINATION WITH MINIMUM TAX.—For
purposes of part VI of subchapter A of this chapter—
‘‘(A) the reference in section 55(b)(2) to tax-
able income shall be treated as a reference to tax-
able income determined without regard to this
subsection,
‘‘(B) the alternative minimum taxable in-
come of any holder of a residual interest in a
REMIC for any taxable year shall in no event
be less than the excess inclusion for such taxable
year, and
202
‘‘(C) any excess inclusion shall be dis-
regarded for purposes of computing the alter-
native tax net operating loss deduction.
The preceding sentence shall not apply to any organi-
zation to which section 593 applies, except to the ex-
tent provided in regulations prescribed by the Sec-
retary under paragraph (2).’’
(2) EFFECTIVE DATE.—The amendment made by
paragraph (1) shall take effect as if included in the
amendments made by section 671 of the Tax Reform
Act of 1986 unless the taxpayer elects to apply such
amendment only to taxable years beginning after the
date of the enactment of this Act.
(j) EXEMPTION FROM HARBOR MAINTENANCE TAX
FOR CERTAIN PASSENGERS.—
(1) IN GENERAL.—Subparagraph (D) of section
4462(b)(1) (relating to special rule for Alaska, Ha-
waii, and possessions) is amended by inserting before
the period the following: ‘‘, or passengers transported
on United States flag vessels operating solely within
the State waters of Alaska or Hawaii and adjacent
international waters’’.
(2) EFFECTIVE DATE.—The amendment made by
paragraph (1) shall take effect as if included in the
203
amendments made by section 1402(a) of the Harbor
Maintenance Revenue Act of 1986.
(k) AMENDMENTS RELATED TO REVENUE PROVISIONS
OF ENERGY POLICY ACT OF 1992.—
(1) Effective with respect to taxable years begin-
ning after December 31, 1990, subclause (II) of sec-
tion 53(d)(1)(B)(iv) is amended to read as follows:
‘‘(II) the adjusted net minimum
tax for any taxable year is the amount
of the net minimum tax for such year
increased in the manner provided in
clause (iii).’’
(2) Subsection (g) of section 179A is redesignated
as subsection (f).
(3) Subparagraph (E) of section 6724(d)(3) is
amended by striking ‘‘section 6109(f)’’ and inserting
‘‘section 6109(h)’’.
(4)(A) Subsection (d) of section 30 is amended—
(i) by inserting ‘‘(determined without re-
gard to subsection (b)(3))’’ before the period at
the end of paragraph (1) thereof, and
(ii) by adding at the end thereof the follow-
ing new paragraph:
‘‘(4) ELECTION TO NOT TAKE CREDIT.—No credit
shall be allowed under subsection (a) for any vehicle
204
if the taxpayer elects to not have this section apply
to such vehicle.’’
(B) Subsection (m) of section 6501 (as redesig-
nated by section 1602) is amended by striking ‘‘sec-
tion 40(f)’’ and inserting ‘‘section 30(d)(4), 40(f)’’.
(5) Subclause (III) of section 501(c)(21)(D)(ii) is
amended by striking ‘‘section 101(6)’’ and inserting
‘‘section 101(7)’’ and by striking ‘‘1752(6)’’ and in-
serting ‘‘1752(7)’’.
(6) Paragraph (1) of section 1917(b) of the En-
ergy Policy Act of 1992 shall be applied as if ‘‘at a
rate’’ appeared instead of ‘‘at the rate’’ in the mate-
rial proposed to be stricken.
(7) Paragraph (2) of section 1921(b) of the En-
ergy Policy Act of 1992 shall be applied as if a
comma appeared after ‘‘(2)’’ in the material proposed
to be stricken.
(8) Subsection (a) of section 1937 of the Energy
Policy Act of 1992 shall be applied as if ‘‘Subpart B’’
appeared instead of ‘‘Subpart C’’.
(l) TREATMENT OF QUALIFIED FOOTBALL COACHES
PLAN.—
(1) IN GENERAL.—Subparagraph (F) of section
3(37) of the Employee Retirement Income Security
Act of 1974 (29 U.S.C. 1002(37)(F)) is amended by
205
redesignating clause (ii) as clause (iii) and by insert-
ing after clause (i) the following new clause:
‘‘(ii) For purposes of the Internal Revenue Code of
1986—
‘‘(I) clause (i) shall apply, and
‘‘(II) a qualified football coaches plan shall be
treated as a multiemployer collectively bargained
plan.’’.
(2) EFFECTIVE DATE.—The amendment made by
paragraph (1) shall apply to years beginning after
December 22, 1987.
(m) DETERMINATION OF UNRECOVERED INVESTMENT
IN ANNUITY CONTRACT.—
(1) IN GENERAL.—Subparagraph (A) of section
72(b)(4) is amended by inserting ‘‘(determined with-
out regard to subsection (c)(2))’’ after ‘‘contract’’.
(2) EFFECTIVE DATE.—The amendment made by
paragraph (1) shall take effect as if included in the
amendments made by section 1122(c) of the Tax Re-
form Act of 1986.
(n) MODIFICATIONS
TO
ELECTION
TO
INCLUDE
CHILD’S INCOME ON PARENT’S RETURN.—
(1) ELIGIBILITY FOR ELECTION.—Clause (ii) of
section 1(g)(7)(A) (relating to election to include cer-
206
tain unearned income of child on parent’s return) is
amended to read as follows:
‘‘(ii) such gross income is more than
the 
amount 
described 
in 
paragraph
(4)(A)(ii)(I) and less than 10 times the
amount so described,’’.
(2) COMPUTATION OF TAX.—Subparagraph (B)
of section 1(g)(7) (relating to income included on par-
ent’s return) is amended—
(A) by striking ‘‘$1,000’’ in clause (i) and
inserting ‘‘twice the amount described in para-
graph (4)(A)(ii)(I)’’, and
(B) by amending subclause (II) of clause
(ii) to read as follows:
‘‘(II) for each such child, 15 per-
cent of the lesser of the amount de-
scribed in paragraph (4)(A)(ii)(I) or
the excess of the gross income of such
child over the amount so described,
and’’.
(3) MINIMUM TAX.—Subparagraph (B) of section
59(j)(1) is amended by striking ‘‘$1,000’’ and insert-
ing ‘‘twice the amount in effect for the taxable year
under section 63(c)(5)(A)’’.
207
(4) EFFECTIVE DATE.—The amendments made
by this subsection shall apply to taxable years begin-
ning after December 31, 1995.
(o) TREATMENT OF CERTAIN VETERANS’ REEMPLOY-
MENT RIGHTS.—
(1) IN GENERAL.—Section 414 is amended by
adding at the end the following new subsection:
‘‘(u) SPECIAL RULES RELATING TO VETERANS’ REEM-
PLOYMENT RIGHTS UNDER USERRA.—
‘‘(1) TREATMENT
OF
CERTAIN
CONTRIBUTIONS
MADE
PURSUANT
TO
VETERANS’ 
REEMPLOYMENT
RIGHTS.—If any contribution is made by an em-
ployer or an employee under an individual account
plan with respect to an employee, or by an employee
to a defined benefit plan that provides for employee
contributions, and such contribution is required by
reason of such employee’s rights under chapter 43 of
title 38, United States Code, resulting from qualified
military service, then—
‘‘(A) such contribution shall not be subject
to any otherwise applicable limitation contained
in section 402(g), 402(h), 403(b), 404(a), 404(h),
408, 415, or 457, and shall not be taken into ac-
count in applying such limitations to other con-
tributions or benefits under such plan or any
208
other plan, with respect to the year in which the
contribution is made,
‘‘(B) such contribution shall be subject to
the limitations referred to in subparagraph (A)
with respect to the year to which the contribu-
tion relates (in accordance with rules prescribed
by the Secretary), and
‘‘(C) such plan shall not be treated as fail-
ing to meet the requirements of section 401(a)(4),
401(a)(26), 401(k)(3), 401(k)(11), 401(k)(12),
401(m), 403(b)(12), 408(k)(3), 408(k)(6), 408(p),
410(b), or 416 by reason of the making of (or the
right to make) such contribution.
For purposes of the preceding sentence, any elective
deferral or employee contribution made under para-
graph (2) shall be treated as required by reason of the
employee’s rights under such chapter 43.
‘‘(2) REEMPLOYMENT
RIGHTS
UNDER
USERRA
WITH RESPECT TO ELECTIVE DEFERRALS.—
‘‘(A) IN
GENERAL.—For purposes of this
subchapter and section 457, if an employee is en-
titled to the benefits of chapter 43 of title 38,
United States Code, with respect to any plan
which provides for elective deferrals, the em-
ployer sponsoring the plan shall be treated as
209
meeting the requirements of such chapter 43 with
respect to such elective deferrals only if such em-
ployer—
‘‘(i) permits such employee to make ad-
ditional elective deferrals under such plan
(in the amount determined under subpara-
graph (B) or such lesser amount as is elect-
ed by the employee) during the period which
begins on the date of the reemployment of
such employee with such employer and has
the same length as the lesser of—
‘‘(I) the product of 3 and the pe-
riod of qualified military service which
resulted in such rights, and
‘‘(II) 5 years, and
‘‘(ii) makes a matching contribution
with respect to any additional elective defer-
ral made pursuant to clause (i) which
would have been required had such deferral
actually been made during the period of
such qualified military service.
‘‘(B) AMOUNT OF MAKEUP REQUIRED.—The
amount determined under this subparagraph
with respect to any plan is the maximum
amount of the elective deferrals that the individ-
210
ual would have been permitted to make under the
plan in accordance with the limitations referred
to in paragraph (1)(A) during the period of
qualified military service if the individual had
continued to be employed by the employer during
such period and received compensation as deter-
mined under paragraph (7). Proper adjustment
shall be made to the amount determined under
the preceding sentence for any elective deferrals
actually made during the period of such quali-
fied military service.
‘‘(C) ELECTIVE DEFERRAL.—For purposes
of this paragraph, the term ‘elective deferral’ has
the meaning given such term by section
402(g)(3); except that such term shall include
any deferral of compensation under an eligible
deferred compensation plan (as defined in sec-
tion 457(b)).
‘‘(D) AFTER-TAX
EMPLOYEE
CONTRIBU-
TIONS.—References in subparagraphs (A) and
(B) to elective deferrals shall be treated as in-
cluding references to employee contributions.
‘‘(3) CERTAIN RETROACTIVE ADJUSTMENTS NOT
REQUIRED.—For purposes of this subchapter and sub-
211
chapter E, no provision of chapter 43 of title 38,
United States Code, shall be construed as requiring—
‘‘(A) any crediting of earnings to an em-
ployee with respect to any contribution before
such contribution is actually made, or
‘‘(B) any allocation of any forfeiture with
respect to the period of qualified military service.
‘‘(4) LOAN
REPAYMENT
SUSPENSIONS
PER-
MITTED.—If any plan suspends the obligation to
repay any loan made to an employee from such plan
for any part of any period during which such em-
ployee is performing service in the uniformed services
(as defined in chapter 43 of title 38, United States
Code), whether or not qualified military service, such
suspension shall not be taken into account for pur-
poses of section 72(p), 401(a), or 4975(d)(1).
‘‘(5) QUALIFIED MILITARY SERVICE.—For pur-
poses of this subsection, the term ‘qualified military
service’ means any service in the uniformed services
(as defined in chapter 43 of title 38, United States
Code) by any individual if such individual is entitled
to reemployment rights under such chapter with re-
spect to such service.
‘‘(6) INDIVIDUAL ACCOUNT PLAN.—For purposes
of this subsection, the term ‘individual account plan’
212
means any defined contribution plan (including any
tax-sheltered annuity plan under section 403(b), any
simplified employee pension under section 408(k),
any qualified salary reduction arrangement under
section 408(p), and any eligible deferred compensa-
tion plan (as defined in section 457(b)).
‘‘(7) COMPENSATION.—For purposes of sections
403(b)(3), 415(c)(3), and 457(e)(5), an employee who
is in qualified military service shall be treated as re-
ceiving compensation from the employer during such
period of qualified military service equal to—
‘‘(A) the compensation the employee would
have received during such period if the employee
were not in qualified military service, deter-
mined based on the rate of pay the employee
would have received from the employer but for
absence during the period of qualified military
service, or
‘‘(B) if the compensation the employee
would have received during such period was not
reasonably certain, the employee’s average com-
pensation from the employer during the 12-
month period immediately preceding the quali-
fied military service (or, if shorter, the period of
213
employment immediately preceding the qualified
military service).
‘‘(8) USERRA REQUIREMENTS FOR QUALIFIED
RETIREMENT PLANS.—For purposes of this subchapter
and section 457, an employer sponsoring a retirement
plan shall be treated as meeting the requirements of
chapter 43 of title 38, United States Code, only if
each of the following requirements is met:
‘‘(A) An individual reemployed under such
chapter is treated with respect to such plan as
not having incurred a break in service with the
employer maintaining the plan by reason of such
individual’s period of qualified military service.
‘‘(B) Each period of qualified military serv-
ice served by an individual is, upon reemploy-
ment under such chapter, deemed with respect to
such plan to constitute service with the employer
maintaining the plan for the purpose of deter-
mining the nonforfeitability of the individual’s
accrued benefits under such plan and for the
purpose of determining the accrual of benefits
under such plan.
‘‘(C) An individual reemployed under such
chapter is entitled to accrued benefits that are
contingent on the making of, or derived from,
214
employee contributions or elective deferrals only
to the extent the individual makes payment to
the plan with respect to such contributions or de-
ferrals. No such payment may exceed the amount
the individual would have been permitted or re-
quired to contribute had the individual remained
continuously employed by the employer through-
out the period of qualified military service. Any
payment to such plan shall be made during the
period beginning with the date of reemployment
and whose duration is 3 times the period of the
qualified military service (but not greater than
5 years).
‘‘(9) PLANS NOT SUBJECT TO TITLE 38.—This
subsection shall not apply to any retirement plan to
which chapter 43 of title 38, United States Code, does
not apply.
‘‘(10) REFERENCES.—For purposes of this sec-
tion, any reference to chapter 43 of title 38, United
States Code, shall be treated as a reference to such
chapter as in effect on December 12, 1994 (without re-
gard to any subsequent amendment).’’
(2) EFFECTIVE DATE.—The amendment made by
this subsection shall be effective as of December 12,
1994.
215
(p) REPORTING OF REAL ESTATE TRANSACTIONS.—
(1) IN
GENERAL.—Paragraph (3) of section
6045(e) (relating to prohibition of separate charge for
filing return) is amended by adding at the end the
following new sentence: ‘‘Nothing in this paragraph
shall be construed to prohibit the real estate reporting
person from taking into account its cost of complying
with such requirement in establishing its charge
(other than a separate charge for complying with such
requirement) to any customer for performing services
in the case of a real estate transaction.’’
(2) EFFECTIVE DATE.—The amendment made by
paragraph (1) shall take effect as if included in sec-
tion 1015(e)(2)(A) of the Technical and Miscellaneous
Revenue Act of 1988.
(q) CLARIFICATION OF DENIAL OF DEDUCTION FOR
STOCK REDEMPTION EXPENSES.
(1) IN
GENERAL.—Paragraph (1) of section
162(k) is amended by striking ‘‘the redemption of its
stock’’ and inserting ‘‘the reacquisition of its stock or
of the stock of any related person (as defined in sec-
tion 465(b)(3)(C))’’.
(2) CERTAIN
DEDUCTIONS
PERMITTED.—Sub-
paragraph (A) of section 162(k)(2) is amended by
striking ‘‘or’’ at the end of clause (i), by redesignating
216
clause (ii) as clause (iii), and by inserting after
clause (i) the following new clause:
‘‘(ii) deduction for amounts which are
properly allocable to indebtedness and am-
ortized over the term of such indebtedness,
or’’.
(3) CLERICAL
AMENDMENT.—The subsection
heading for subsection (k) of section 162 is amended
by striking ‘‘REDEMPTION’’ and inserting ‘‘REACQUI-
SITION’’.
(4) EFFECTIVE DATE.—
(A) IN GENERAL.—Except as provided in
subparagraph (B), the amendments made by this
subsection shall apply to amounts paid or in-
curred after September 13, 1995, in taxable
years ending after such date.
(B) 
PARAGRAPH
(2).—The 
amendment
made by paragraph (2) shall take effect as if in-
cluded in the amendment made by section 613 of
the Tax Reform Act of 1986.
(r) CLERICAL AMENDMENT TO SECTION 404.—
(1) IN
GENERAL.—Paragraph (1) of section
404(j) is amended by striking ‘‘(10)’’ and inserting
‘‘(9)’’.
217
(2) EFFECTIVE DATE.—The amendment made by
paragraph (1) shall take effect as if included in the
amendments made by section 713(d)(4)(A) of the Def-
icit Reduction Act of 1984.
(s) PASSIVE INCOME NOT TO INCLUDE FSC INCOME,
ETC.—
(1) IN
GENERAL.—Paragraph (2) of section
1296(b) is amended by striking ‘‘or’’ at the end of
subparagraph (B), by striking the period at the end
of subparagraph (C) and inserting ‘‘, or’’, and by in-
serting after subparagraph (C) the following new sub-
paragraph:
‘‘(D) which is foreign trade income of a
FSC or export trade income of an export trade
corporation (as defined in section 971).’’
(2) EFFECTIVE DATE.—The amendment made by
paragraph (1) shall take effect as if included in the
amendments made by section 1235 of the Tax Reform
Act of 1986.
(t) MISCELLANEOUS CLERICAL AMENDMENTS.—
(1) Subclause (II) of section 56(g)(4)(C)(ii) is
amended by striking ‘‘of the subclause’’ and inserting
‘‘of subclause’’.
(2) Paragraph (2) of section 72(m) is amended
by inserting ‘‘and’’ at the end of subparagraph (A),
218
by striking subparagraph (B), and by redesignating
subparagraph (C) as subparagraph (B).
(3) Paragraph (2) of section 86(b) is amended by
striking ‘‘adusted’’ and inserting ‘‘adjusted’’.
(4)(A) The heading for section 112 is amended
by striking ‘‘COMBAT PAY’’ and inserting ‘‘COMBAT
ZONE COMPENSATION’’.
(B) The item relating to section 112 in the table
of sections for part III of subchapter B of chapter 1
is amended by striking ‘‘combat pay’’ and inserting
‘‘combat zone compensation’’.
(C) Paragraph (1) of section 3401(a) is amended
by striking ‘‘combat pay’’ and inserting ‘‘combat zone
compensation’’.
(5) Clause (i) of section 172(h)(3)(B) is amended
by striking the comma at the end thereof and insert-
ing a period.
(6) Clause (ii) of section 543(a)(2)(B) is amend-
ed by striking ‘‘section 563(c)’’ and inserting ‘‘section
563(d)’’.
(7) Paragraph (1) of section 958(a) is amended
by striking ‘‘sections 955(b)(1) (A) and (B),
955(c)(2)(A)(ii), and 960(a)(1)’’ and inserting ‘‘sec-
tion 960(a)(1)’’.
219
(8) Subsection (g) of section 642 is amended by
striking ‘‘under 2621(a)(2)’’ and inserting ‘‘under
section 2621(a)(2)’’.
(9) Section 1463 is amended by striking ‘‘this
subsection’’ and inserting ‘‘this section’’.
(10) Subsection (k) of section 3306 is amended
by inserting a period at the end thereof.
(11) The item relating to section 4472 in the
table of sections for subchapter B of chapter 36 is
amended by striking ‘‘and special rules’’.
(12) Paragraph (3) of section 5134(c) is amend-
ed by striking ‘‘section 6662(a)’’ and inserting ‘‘sec-
tion 6665(a)’’.
(13) Paragraph (2) of section 5206(f) is amended
by striking ‘‘section 5(e)’’ and inserting ‘‘section
105(e)’’.
(14) Paragraph (1) of section 6050B(c) is
amended by striking ‘‘section 85(c)’’ and inserting
‘‘section 85(b)’’.
(15) Subsection (k) of section 6166 is amended
by striking paragraph (6).
(16) Subsection (e) of section 6214 is amended to
read as follows:
220
‘‘(e) CROSS REFERENCE.—
‘‘For provision giving Tax Court jurisdiction to
order a refund of an overpayment and to award
sanctions, see section 6512(b)(2).’’
(17) The section heading for section 6043 is
amended by striking the semicolon and inserting a
comma.
(18) The item relating to section 6043 in the
table of sections for subpart B of part III of sub-
chapter A of chapter 61 is amended by striking the
semicolon and inserting a comma.
(19) The table of sections for part I of subchapter
A of chapter 68 is amended by striking the item relat-
ing to section 6662.
(20)(A) Section 7232 is amended—
(i) by striking ‘‘LUBRICATING OIL,’’ in
the heading, and
(ii) by striking ‘‘lubricating oil,’’ in the
text.
(B) The table of sections for part II of sub-
chapter A of chapter 75 is amended by striking ‘‘lu-
bricating oil,’’ in the item relating to section 7232.
(21) Paragraph (1) of section 6701(a) of the Om-
nibus Budget Reconciliation Act of 1989 is amended
by striking ‘‘subclause (IV)’’ and inserting ‘‘subclause
(V)’’.
221
(22) Clause (ii) of section 7304(a)(2)(D) of such
Act is amended by striking ‘‘subsection (c)(2)’’ and
inserting ‘‘subsection (c)’’.
(23) Paragraph (1) of section 7646(b) of such
Act is amended by striking ‘‘section 6050H(b)(1)’’
and inserting ‘‘section 6050H(b)(2)’’.
(24) Paragraph (10) of section 7721(c) of
such 
Act 
is 
amended 
by 
striking 
‘‘section
6662(b)(2)(C)(ii)’’ 
and 
inserting 
‘‘section
6661(b)(2)(C)(ii)’’.
(25) Subparagraph (A) of section 7811(i)(3) of
such Act is amended by inserting ‘‘the first place it
appears’’ before ‘‘in clause (i)’’.
(26) Paragraph (10) of section 7841(d) of
such Act is amended by striking ‘‘section 381(a)’’
and inserting ‘‘section 381(c)’’.
(27) Paragraph (2) of section 7861(c) of such Act
is amended by inserting ‘‘the second place it appears’’
before ‘‘and inserting’’.
(28) Paragraph (1) of section 460(b) is amended
by striking ‘‘the look-back method of paragraph (3)’’
and inserting ‘‘the look-back method of paragraph
(2)’’.
222
(29) Subparagraph (C) of section 50(a)(2) is
amended by striking ‘‘subsection (c)(4)’’ and inserting
‘‘subsection (d)(5)’’.
(30) Subparagraph (B) of section 172(h)(4) is
amended by striking the material following the head-
ing and preceding clause (i) and inserting ‘‘For pur-
poses of subsection (b)(2)—’’.
(31) Subparagraph (A) of section 355(d)(7) is
amended by inserting ‘‘section’’ before ‘‘267(b)’’.
(32) Subparagraph (C) of section 420(e)(1) is
amended by striking ‘‘mean’’ and inserting ‘‘means’’.
(33) Paragraph (4) of section 537(b) is amended
by striking ‘‘section 172(i)’’ and inserting ‘‘section
172(f)’’.
(34) Subparagraph (B) of section 613(e)(1) is
amended by striking the comma at the end thereof
and inserting a period.
(35) Paragraph (4) of section 856(a) is amended
by striking ‘‘section 582(c)(5)’’ and inserting ‘‘section
582(c)(2)’’.
(36) 
Sections 
904(f)(2)(B)(i) 
and
907(c)(4)(B)(iii) are each amended by inserting ‘‘(as
in effect on the day before the date of the enactment
of the Revenue Reconciliation Act of 1990)’’ after
‘‘section 172(h)’’.
223
(37) Subsection (b) of section 936 is amended by
striking ‘‘subparagraphs (D)(ii)(I)’’ and inserting
‘‘subparagraphs (D)(ii)’’.
(38) Subsection (c) of section 2104 is amended
by striking ‘‘subparagraph (A), (C), or (D) of section
861(a)(1)’’ and inserting ‘‘section 861(a)(1)(A)’’.
(39) Subparagraph (A) of section 280A(c)(1) is
amended to read as follows:
‘‘(A) as the principal place of business for
any trade or business of the taxpayer,’’.
(40) Section 6038 is amended by redesignating
the subsection relating to cross references as subsection
(f).
(41) Clause (iv) of section 6103(e)(1)(A) is
amended by striking all that follows ‘‘provisions of’’
and inserting ‘‘section 1(g) or 59(j);’’.
(42) The subsection (f) of section 6109 of the In-
ternal Revenue Code of 1986 which was added by sec-
tion 2201(d) of Public Law 101–624 is redesignated
as subsection (g).
(43) Subsection (b) of section 7454 is amended
by striking ‘‘section 4955(e)(2)’’ and inserting ‘‘sec-
tion 4955(f)(2)’’.
(44) Subsection (d) of section 11231 of the Reve-
nue Reconciliation Act of 1990 shall be applied as if
224
‘‘comma’’ appeared instead of ‘‘period’’ and as if the
paragraph (9) proposed to be added ended with a
comma.
(45) Paragraph (1) of section 11303(b) of the
Revenue Reconciliation Act of 1990 shall be applied
as if ‘‘paragraph’’ appeared instead of ‘‘subpara-
graph’’ in the material proposed to be stricken.
(46) Subsection (f) of section 11701 of the Reve-
nue Reconciliation Act of 1990 is amended by insert-
ing ‘‘(relating to definitions)’’ after ‘‘section 6038(e)’’.
(47) Subsection (i) of section 11701 of the Reve-
nue Reconciliation Act of 1990 shall be applied as if
‘‘subsection’’ appeared instead of ‘‘section’’ in the ma-
terial proposed to be stricken.
(48) Subparagraph (B) of section 11801(c)(2) of
the Revenue Reconciliation Act of 1990 shall be ap-
plied as if ‘‘section 56(g)’’ appeared instead of ‘‘sec-
tion 59(g)’’.
(49) Subparagraph (C) of section 11801(c)(8) of
the Revenue Reconciliation Act of 1990 shall be ap-
plied as if ‘‘reorganizations’’ appeared instead of ‘‘re-
organization’’ in the material proposed to be stricken.
(50) Subparagraph (H) of section 11801(c)(9) of
the Revenue Reconciliation Act of 1990 shall be ap-
225
plied as if ‘‘section 1042(c)(1)(B)’’ appeared instead
of ‘‘section 1042(c)(2)(B)’’.
(51) Subparagraph (F) of section 11801(c)(12) of
the Revenue Reconciliation Act of 1990 shall be ap-
plied as if ‘‘and (3)’’ appeared instead of ‘‘and (E)’’.
(52) Subparagraph (A) of section 11801(c)(22) of
the Revenue Reconciliation Act of 1990 shall be ap-
plied as if ‘‘chapters 21’’ appeared instead of ‘‘chap-
ter 21’’ in the material proposed to be stricken.
(53) Paragraph (3) of section 11812(b) of the
Revenue Reconciliation Act of 1990 shall be applied
by not executing the amendment therein to the head-
ing of section 42(d)(5)(B).
(54) Clause (i) of section 11813(b)(9)(A) of the
Revenue Reconciliation Act of 1990 shall be applied
as if a comma appeared after ‘‘(3)(A)(ix)’’ in the ma-
terial proposed to be stricken.
(55) Subparagraph (F) of section 11813(b)(13)
of the Revenue Reconciliation Act of 1990 shall be ap-
plied as if ‘‘tax’’ appeared after ‘‘investment’’ in the
material proposed to be stricken.
(56) Paragraph (19) of section 11813(b) of the
Revenue Reconciliation Act of 1990 shall be applied
as if ‘‘Paragraph (20) of section 1016(a), as redesig-
226
nated by section 11801,’’ appeared instead of ‘‘Para-
graph (21) of section 1016(a)’’.
(57) Paragraph (5) section 8002(a) of the Sur-
face Transportation Revenue Act of 1991 shall be ap-
plied as if ‘‘4481(e)’’ appeared instead of ‘‘4481(c)’’.
(58) Section 7872 is amended—
(A) by striking ‘‘foregone’’ each place it ap-
pears in subsections (a) and (e)(2) and inserting
‘‘forgone’’, and
(B) by striking ‘‘FOREGONE’’ in the heading
for subsection (e) and the heading for paragraph
(2) of subsection (e) and inserting ‘‘FORGONE’’.
(59) Paragraph (7) of section 7611(h) is amend-
ed by striking ‘‘approporiate’’ and inserting ‘‘appro-
priate’’.
(60) The heading of paragraph (3) of section
419A(c) is amended by striking ‘‘SEVERENCE’’ and
inserting ‘‘SEVERANCE’’.
(61) Clause (ii) of section 807(d)(3)(B) is
amended by striking ‘‘Commissoners’ ’’ and inserting
‘‘Commissioners’ ’’.
(62) Subparagraph (B) of section 1274A(c)(1) is
amended by striking ‘‘instument’’ and inserting ‘‘in-
strument’’.
227
(63) Subparagraph (B) of section 724(d)(3) by
striking ‘‘Subparagaph’’ and inserting ‘‘Subpara-
graph’’.
(64) The last sentence of paragraph (2) of section
42(c) is amended by striking ‘‘of 1988’’.
(65) Paragraph (1) of section 9707(d) is amend-
ed by striking ‘‘diligence,’’ and inserting ‘‘diligence’’.
(66) Subsection (c) of section 4977 is amended
by striking ‘‘section 132(i)(2)’’ and inserting ‘‘section
132(h)’’.
(67) The last sentence of section 401(a)(20) is
amended by striking ‘‘section 211’’ and inserting
‘‘section 521’’.
(68) Subparagraph (A) of section 402(g)(3) is
amended by striking ‘‘subsection (a)(8)’’ and insert-
ing ‘‘subsection (e)(3)’’.
(69) The last sentence of section 403(b)(10) is
amended by striking ‘‘an direct’’ and inserting ‘‘a
direct’’.
(70) Subparagraph (A) of section 4973(b)(1) is
amended by striking ‘‘sections 402(c)’’ and inserting
‘‘section 402(c)’’.
(71) Paragraph (12) of section 3405(e) is
amended by striking ‘‘(b)(3)’’ and inserting ‘‘(b)(2)’’.