REVENUE ACT OF 1951
Document Type:
Collection:
Document Number (FOIA) /ESDN (CREST):
CIA-RDP57-00384R001200010010-8
Release Decision:
RIFPUB
Original Classification:
K
Document Page Count:
32
Document Creation Date:
December 20, 2016
Document Release Date:
July 11, 2001
Sequence Number:
10
Case Number:
Publication Date:
October 15, 1951
Content Type:
REPORT
File:
Attachment | Size |
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Body:
Approved For Release 2007/02/24: CIA-RDP57-00384R001200010010-8
82n CONGRESS. HOUSE OF REPRESENTATIVES I REPORT
1st Session No. 1179
REVENUE ACT OF 1951
OCTOBER 15, 1951.-Ordered to be printed
Mr. DOUGHTON, from the committee of conference, submitted the
following
CONFERENCE REPORT
[To accompany II. R. 4473]
The committee of conference on the disagreeing votes of the two
Houses on the amendments of the Senate to the bill (H. R. 4473),
to provide revenue, and for other purposes, having met, after full
and free conference, have agreed to recommend. and do recommend
to their respective Houses as follows:
That the Senate recede from its amendments numbered 2, 3, 5,
94, 98, 119, 120, 123, 124, 125, 126, 130, 132, 133, 134, 135, 136, 138,
139, 140, 144, 145, 146, 147, 148, 149, 150, 152, 155, 157, 158, 159,
160, 161, 162, 164, 165, 170, 177, 182, 183, 201, 202, and 203.
That the House recede from its disagreement to the amendments
of the Senate numbered 9, 10, 11, 12, 14, 15, 1.6, 17, 18, 19, 20, 21,
22, 23, 24, 25, 26, 27, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41,
42, 44, 47, 48, 49, 50, 51, 52, 56, 57, 58, 59, 60, 61, 62, 63, 65, 66, 68,
69, 70, 71, 72, 73, 74, 75, 76, 87, 95, 103, 105, 106, 108, 109, 112, 113,
114, 115, 116, 117, 153, 169, 171, 176, 180, 186, 187, 189, 190, 192,
195, 196, 204, 205, 206, 207, 208, 209, 212, 218, 223, 229, 230, 232,
233, 242, 243, and 244 and agree to the same.
90547-51--1
Approved. For Release 2007/02/24: CIA-RDP57-00384R001200010010-8
Approved For Release 2007/02/24: CIA-RDP5.7-00384R001200010010-8
2 REVENUE ACT OF 1951
Amendment numbered 1:
That the House recede from its disagreement to the amendment of
the Senate numbered 1, and agree to the same with the following
amendments:
Strike out the surtax table beginning on page 1 of the Senate
engrossed amendments and insert the following:
"If the surtax net income is: The surtax shall be:
Not over $2,000___________________
17.4% of the surtax net income.
Over $2,000 but not over $4,000 ------
$348, plus 19.4% of excess over $2,000. f
Over $4,000 but not over $6,000 ------
$736, plus 24% o excess over $4,000.
Over $6,000 but not over $8,000! _____
$1,216, plus 27% of excess over $6,000.
Over $8,000 but not over $10,000_____
$1,756, plus 32% of excess over $8,000.
Over $10,000 but not over $12,000____
$2,396, plus 36% of excess over $10,000.
Over $12,000 but not over $14,000___-
$3,116, plus 40% of excess over $12,000.
Over $14,000 but not over $16,000____
$3,916, plus 45% of excess over $14,000.
Over $16,000 but not over $18,000____
$4,816, plus 48% of excess over $16,000.
Over $18,000 but not over $20,000____
$5,776, plus 61 % of excess over $18,000.
Over $20,000 but not over $22,000____
$6,796, plus 64%of excess over $20,000.
Over $22,000 but not over $26,000___-
$7,876, plus 57 %a of excess over $22,000.
000 but not over $32,000____
Over $26
$10,156, plus 60% of excess over
,
$26,000.
000 but not over $38,000____
Over $32
$13,756, plus 63% of excess over
,
$32,000.
000 but not over $44,000__-_
Over $38
$17,536, plus 66% of excess over
,
$88,000.
Over $44,000 but not over $50,000____
$21,496, plus 70% of excess over
$44,000.
000 but not over $60,000____
Over $50
$26,696, plus 72 % of excess over
,
$50,000.
Over $60,000 but not over $70,000____
$32,896, plus 75% of excess over
$60,000.
000 but not over $80,000____
Over $70
$40,396, plus 79% of excess over
,
$70,000.
Over $80,000 but not over $90,000____
$48,296, plus 815/o of excess over
$80,000.
000 but not over $100,000___
Over $90
$56,396, plus 84% of excess over
,
$90,000.
Over $100,000 but not over $150,000_-
$64,796, plus 86% of excess over
$100,000.
000 but not over $200,000__
Over $150
$107,796, plus 87% of excess over
,
$150,000.
Over P200,000 --------------------
lus 88% of excess over
$161,296, $200,000.:
Approved For Release 2007/02/24: CIA-RDP57-00384R001200010010-8
Approved For Release 2007/02/24: CIA-RDP57-00384R001200010010-8
REVENUE ACT OF 1951 3
Strike out the surtax table on page 3 of the Senate engrossed
amendments and insert the following:
"If the surtax net income is:
The surtax shall be:
Not over $2,000-------------------
19.3% of the surtax net income.
Over $2,000 but not over $4,000 ------
$386, plus 21.6% of excess over $2,000.
Over $4,000 but not over $6,000______
$818, plus 26% of excess over $4,000.
Over $6,000 but not over $8,000______
$1,338, plus 31% of excess over $6,000.
Over $8,000 but not over $10,000_____
$1,958, plus 35% of excess over $8,000.
Over $10,000 but not over $12,000___ _
$2,658, plus 39% of excess over $10,000.
Over $12,000 but not over $14,000___ _
$3,438, plus 45% of excess over $12,000.
Over $14,000 but not over $16,000____
$4,338, plus 50% of excess over $14,000.
Over $16,000 but not over $18,000____
$5,338, plus 530 of excess over $16,000.
Over $18,000 but not over $20,000____
$6,398, plus 56% of excess over $18,000.
Over $20,000 but not over $22,000___-
$7,518, plus 59% of excess over $20,000.
Over $22,000 but not over $26,000____
$8,698, plus 63%of excess over $22,000.
Over $26,000 but not over $32,000____
$11,218, plus 64% of excess over
$26,000.
Over $32,000 but not over $38,000-___
$15,058, plus 65% of excess over
$32,000.
Over $38,000 but not over $44,000____
$18,958, plus 69% of excess over
$38,000.
Over $44,000 but not over $50,000____
$23,098, plus 72% of excess over
$44,000.
Over $50,000 but not over $60,000___-
$27,418, plus 74% of excess over
$50,000.
Over $60,000 but not over $70,000_-__
$34,818, plus 77% of excess over
$60,000.
Over $70,000 but not over $80,000____
$42,518, plus 80% of excess over
$70,000.
Over $80,000 but not over $90,000____
$50,518, plus 82% of excess over
$80,000.
Over $90,000 but not over $100,000__-
$58,718, plus 85% of excess over
$90,000.
Over $100,000 but not over $150,000__
$67,218, plus 87% of excess over
$100,000.
Over $150,000 but not over $200,000_-
$110,718, plus 88% of excess over
$150,000.
Over $200,000-------------------- $154,718, plus 89% of excess over
$200,000.
Strike out the tables on pages 7 and 8 of the Senate engrossed
amendments and insert the following:
Approved For Release 2007/02/24: CIA-RDP57-00384R001200010010-8
Approved For Release 2007/02/24: CIA-RDP57-00384R001200010010-8
4 REVENUE ACT OF 1951
"Table II
"Taxable years beginning after October 31, 1951, and before January 1, 1954
$0 $675 $0 $0 $0 $0 $2,$25 $2,350 $335 $335 $202 $202 $202 $68 $68 $68 $0 $0 $0$0 $0
675 700 4 0 0 0 2,350 2,375 340 340 207 207 807 73 73 73 0 0 0 0 0 Aio~
700 725 9 0 0 0 2,376 2,400 445 346 212 212 212 78 78 78 0 0 0 0 0
725 750 14 0 0 0 2,400 2,425 350 350 217 $117 217 83 83 83 0 0 0 0 0
750 776 19 0 0 0 2,426 2,450 355 355 222 222 222 88 88 88 0 0 0 0 0
775 800 24 0 0 0 2, 450 2, 475 360 360 227 227 227 93 93 93 0 0 0 0 0
800 825 99 0 0 0 2,475 2,500 365 365 232 232 232 98 98 98 0 0 0 0 0
825 850 34 0 0 0 2,600 2,525 370 370 237 237 237 103 103 103 0 0 0 0 0
850 875 39 0 0 0 2,525 2,550 376 375 242 242 242 108 108 108 0 0 0 0 0
875 900 44 0 0 0 2,550 2,575 380 380 247 247 247 113 113 113 0 0 0 0 0
900 925 49 0 0 0 2,575 2,600 386 386 252 252 252 118 118 118 0 0 0 0 0
925 950 54 0 0 0 2,600 2,626 391 391 257 257 257 123 123 123 0 0 0 0 0
960 976 59 0 0 0 2,625 2,650 396 396 262 202 202 128 128 128 0 0 0 0 0
976 1,000 64 1 0 0 2,650 2,675 401 401 267 207 967 133 133 133 0 0 0 0 0
1,0001,025 69 0 0 0 2,675 2,700 406 406 272 272 272 138 138 138 4 0 0 0 0
1,0251,050 74 0 0 0 2,700 2,725 411 411 277 277 977 14,4 143 14,4 9 0 0 0 0
1,060 1,076 79 0 0 0 2,725 2,750 416 416 $182 282 282 148 148 148 14 0 .0 0 0
1,076 1,100 84 0 0 0 2,750 2,776 421 421 287 287 287 153 153 153 19 0 0 0 0
1,100 1,126 89 0 0 0 2,775 2,800 426 426 292 292 292 158 158 158 24 0 0 0 0
1, 2251,150 94 0 0 0 2,800 2,825 431 481 297 297 297 163 163 163 29 0 0 0 0
1,1501,176 100 0 0 0 2, 825 2, 860 436 436 302 302 302 168 168 168 34 0 0 0 0
1,175 1,200 106 0 0 0 2, 850 2, 875 441 441 307 .407 307 173 173 173 39 0 0 0 0
900 446 446 312 312 812 178 178 178 44 0 0 0 0
875 2
225 110 0 0 0 2
1
200 1
If adjust-
And the
If adjust-
ed gross
number of
ed gross
And the number of exemptions Is-
income
exemptions
income
is-
is-
is-
1
2
3
And
And
tax-
And
And
taAnd
x-
And
And
But
1
2
4 or
3
pager
is single
-
tax
pager
payer
is single
tax-
payer
a
joint
payer
is single
tax-
pager
a
joint
4
5
6
8 or
7
At
least
less
more
At
But
leas
or
i
d
is
head
or
i
d
is
head
-
re
t
or
ma
ied
is
head
re-
turn
more
than
least
th
an
marr
e
filing
of
house -
marr
e
filing
of
house-
urn
is
rr
filing
of
house_
is
sepa-
ratelg
hold
sepa-
ratelg
hold
filed
sepa-
ratelg
hold
filed
s
Th
hal
e tax
l be-
Th
e tax
shall be
-
,
,
,
,
1,250 115
1,226
0
0 0
2,900
2,925
451
461
817
317
317
188
183
183
49
0
0
0 0
1,250 1,276120
0
0 0
2, 926
2, 950
457
456
322
322
822
188
188
188
64
0
0
0 0
1,276 1,300125
0
0 0
2, 950
2, 975
462
461
327
327
327
193
193
193
59
0
0
0 0
1,300 1,325 130
0
0 0
2,975
3,000
468
467
332
332
332
198
198
198
64
0
0
0 0
1325 1,350 186
1
0 . 0
8,000
3,050
476
476
340
340
340
206
206
206
72
0
0
0 0
1: 350 1,875 140
6
0 0
8,050
3,100
487
485
360
460
360
216
216
216
82
0
0
0 0
1,
16
,4$
6
:11
0 0
3,1
50
81,60
98
6
96
6
860
860
80
7
226
226
2,*6
92
0
0
0 0
1
61
0
16
0 0
8,1
3,200
09
06
370
370
3
0
236
236
236
102
0
0
0 0
1, 4251, 4502165
21
0 0
8, 200
8, 260
520
617
$80
. 380
380
246
246
246
112
0
0
0 0
1,450 1,475160
26
0 0
3,250
3,300
532
527
390
390
390
256
256
256
122
0
0
0 0
1:476 1,600165
31
0 0
3,300
3,350
543
638
400
400
400
266
266
266
132
0
0
0 0
1, 5001,526 170
36
0 0
3,350
3,400
554
548
410
410
410
276
276
276
142
8
0
0 0
1, 6251, 550175
41
0 0
3,400
3,450
565
559
420
420
420
. 286
286
286
152
18
0
0 0
1,650 1. 675 180
46
0 0
3,460
3,500
576
569
430
430
430
296
296
296
162
28
0
0 0
1 676 1, 600 186
,
61
0 0
3,500
8,560
587
580
440
440
440
306
806
306
172
38
0
0 0
1, 600 1.625190
56
0 0
3,550
3,600
598
500
450
450
460
316
316
316
182
49
0
0 0
16251, 660 196
Of
0 0
3,600
3,660
609
601
461
461
460
326
326
326
192
59
0
0 0
1:650 1, 675'200
66
0 0
8,650
3,700
620
612
472
472
470
336
336
836
202
69
0
0 0
1, 676 1:70 205
71
0 0
8,700
8,750
631
622
484
482
480
346
346
346
212
79
0
0 0
1:700 1,726210
76
0 0
8,750
8,800
642
633
495
492
490
356
356
366
222
89
0
0 0
1,726 1.760 215
81
0 0
31800
61860
653
643
506
603
500
366
366
366
232
99
0
0 0
1,750 1,776 220
86
0 0
1,11
3, 900
664
664
517
513
610
876
376
376
243
109
0
0 0
1,775 1,800 225
91
0 0
3,000
3,960
675
664
528
524
520
386
$86
386
253
119
0
0 0
1,800 1, 825 230
96
0 0
3,950
4,000
686
075
539
534
530
396
396
396
263
129
0
0 0
1,825 1, 860 235
101
0 0
4,000
4,050
698
685
560
545
540
406
406
406
273
139
5
0 0
1,850 1, 875 940
106
0 0
4,050
4,100
709
696
501
656
550
416
416
416
2-88
149
15
0 0
1, 875 1, 900 245
111
0 0
4,100
4,150
720
706
572
566
560
426
426
426
293
159
25
0 0
1,9001 , 995250
116
0 0
4,150
4,200
731
717
583
576
570
437
437
437
303
169
35
0 0
1,926 1,950 266
121
0 0
4,200
4,250
742
727
594
587
580
447
447
447
313
179
45
0 ' 0
1, 9501, 1,975 280
126
0 0
4,250
4,300
763
738
606
598
590
458
467
457
23
189
55
0 0
1,976 2,000 265
131
0 0
4, 300
4, 350
764
748
616
608
600
469
468
467
333
19,9
65
0 0
2,000 2
0251270
136
3 0
4, 360
4,406
775
759
627
619
610
480
478
477
,348
209
75
0 0
:
2, 0252050,275
'
141
8 0
4,400
4,460
786
770
638
029
620
491
489
487
353
219
85
0 0
2, 0502, 075
,280
146
13 0
4,450
4,500
797
780
650
640
631
502
499
497
363
229
95
0 0
2, 0752,100.285
151
18 0
4,500
4,560
808
791
661
050
641
513
510
607
373
239
105
0 0
2,100 2,126'290
160295
2
1252
156
161
23 0
28 0
4,660
4,600
4,600
4,050
819
830
801
812
672
683
661
671
661
661
624
535
520
631
617
527
383
393
249
269
115
126
0 0
0 0
,
,
2,150 2,176 800
166
33 0
4,650
4,700
841
822
694
682
671
546
641
637
403
269
136
2 0
2,176 2, 200'806
171
38 0
4, 700
4,750
863
833
705
692
681
557
'
552
547
413
279
146
12 0
2, 200 2, 225310
176
43 0
4, 750
4,800
864
843
716
703
691
668
562
557
423
289
156
22 0
2,226 2, 250316
181
48 6
4, 800
4, 860
875
854
727
713
701
579
573
567
433
299
166
32 0
2, 2602, 275!320
186
63 0
4, 850
4, 900
886
864
738
724
711
691
583
677
443
309
276
42 0
2,275 2,300 326
192
58 0
4,900
4, 960
897
876
749
734
721
602
594
587
453
319
186
62 0
R,8 0012, 3261330
197
03 0
4,950
5,000
908
885
760
745
731
613
605
697
4 68
329
196
62 0
Approved For Release 2007/02/24: CIA-RDP57-00384R001200010010-8
Approved For Release 2007/02/24: CIA-RDP57-00384R001200010010-8
REVENUE ACT OF 1951 5
"Table III
"Taxable years beginning after December 31, 1953
$0 $676 $0 $0 $0
675 700 4 0 0 ~/
700 725 8 0 0
' 725 750 18 0 0
If adjust-
And the
If adjust-
ed gross
income
number of
exemptions
ed gross
inco me
And the number of exemptions is-
is-
is-
is-
1
2
3
And
tax-
An
taAnd x-
And
And
tax-
And
And
B
1
2
4 or
3
t
B
payer
is single
Pager
pager
is single
tax-
pager
i
a
joint
payer
is single
tax
pager
i
a
joint
4
5
6
8 or
7
e
At
least
ut
leas
more
At
least
u
less
or
married
Is
head
or
married
s
head
re-
turn
or
married
s
head
re-
turn
mor
than
than
filing
of
horu
filing
of
house-
is
filing
of
house-
is
seAa-
rately
hold
aepa-
rately I
.xold
filed
sepa-
rately
hold
filed
s
Th
hal
e tax
l be-
Th
e tax shall be
-
$0
$2,325
$2,850
$301
$301
$181
$181
$181
$61
$61
$61
$0
$0
$0
$0 $0
0
2,350
2,375
805
805
186
185
186
65
65
65
0
0
0
0 0
0
2,576
2,400
510
810
190
100
190
70
70
70
0
0
0
0 0
0
2,400
2,426
814
514
194
194
194
74
74
74
0
0
0
0 0
750
775
17
0
0 0
2,425
2,450
319
819
199
199
199
79
79
79
0
0
0
0 0
775
800
22
0
0 0
2,460
2,476
823
828
208
208
203
88
83
88
0
0
0
0 0
800
825
26
0
0 0
2,475
2,500
828
828
208
208
208
88
88
88
0
0
0
0 0
825
850
51
0
0 0
2,500
2,526
382
832
212
212
212
92
92
92
0
0
0
0 0
850
875
36
0
0 0
2,525
2,550
837
887
217
217
217
97
97
97
0
0
0
0 0
875
900
40
0
0 0
2,550
2,575
841
841
221
221
221
101
101
10!
0
0
0
0 0
900
925
44
0
0 0
2,575
2,600
840
846
226
226
226
106
106
106
0
0
0
0 0
925
950
49
0
0 0
2,600
2,625
850
850
230
250
230
110
110
110
0
0
0
0 0
950
976
58
0
0 0
2,625
2,650
555
856
255
235
235
115
115
115
0
0
0
0 0
975
1,000
58
0
0 0
2,650
2,675
859
859
239
239
239
119
119
119
0
0
0
0 0
1,000
1,025
62
0
0 0
2,676
2,700
864
864
244
244
244
124
124
124
4
0
f)
0 0
1,025
1,050
67
0
0 0
2,700
2,725
668
868
248
248
248
128
128
128
8
0
0
0 0
7 050
,
1,075
71
0
.
0 0
2,725
2,750
873
873
258
258
268
183
135
133
18
0
0
0 0
1,
076
1 100
,
76
0
0 0
2,750
2,775
877
877
257
257
257
187
187
137
17
0
0
0 0
1 100
,
1,
125
80
0
0
0
2,775
2,800
882
382
262
262
262
142
142
142
22
0
0
0 0
1,
126
1 ,
150
86
0
0 0
2,800
2,825
886
886
266
266
266
146
146
146
26
0
0
0 0
1 150
,
1,
176
80
0
0
0
2,825
2,850
391
391
271
271
271
151
151
151
51
0
0
0 0
175
1,
1,200
94
0
0 0
2,850
2,876
396
896
275
275
275
165
155
155
55
0
0
0 0
1,200
1,225
98
0
0 0
2,875
2,900
400
400
280
280
280
160
160
160
40
0
0
0 0
1,225
1, 250
108
0
0 0
2,900
2,925
405
404
284
284
284
164
164
184
44
0
0
0 0
1,250
1, 275
107
0
0 0
2,925
2,950
410
409
289
289
289
169
169
169
49
0
0
0 0
1 275
,
,
1 300
112
0
0 0
2,950
2,975
415
414
298
298
293
173
173
173
53
0
0
0 0
800
1,
1,
826
116
0
0 0
2,975
8,000
420
419
298
298
298
178
178
178
58
0
0
0 0
1,825
1,850
121
1
0 0
3,000
3,050
427
426
805
505
806
186
186
185
65
0
0
0 0
1,360
1,375
126
5
0 0
3,050
3,100
487
486
514
814
314
194
194
194
74
0
0
0 0
1 376
,
1,400
130
10
0 0
8,100
3,160
447
446
823
328
823
208
203
203
83
0
0
0 0
1,400
1 , 425
134
14
0 0
8,150
3,200
457
464
332
382
332
212
212
212
92
0
0
0 0
1,426
1, 450
139
19
0 0
5,200
3,250
467
464
341
341
541
221
221
221
101
0
0
0 0
1,450
1, 475
143
23
0 0
8,250
8,300
476
478
360
350
560
230
230
230
110
0
0
0 0
1,475
1, 500
148
28
0 0
3,300
8,560
486
482
369
859
869
239
259
239
119
0
0
0 0
1, 600
1, 625
152
32
0 0
3,360
3,400
496
492
368
368
388
248
248
248
128
8
0
0 0
1 625
,
1,500
157
87
0 0
3,400
3,450
506
501
877
377
377
257
257
287
137
17
0
0 0
550
1,
1,575
161
41
0 0
3,460
3,500
516
511
386
386
586
266
266
266
146
26
0
0 0
1,576
1, 600
166
46
0 0
3,500
8,660
526
520
395
395
396
276
275
275
166
35
0
0 0
1,600
1, 625
170
50
0 0
3,550
3,600
586
680
404
404
404
284
284
284
164
44
0
0 0
1,625
1, 650
175
55
0 0
8,600
3,650
646
689
414
415
418
293
293
208
173
58
0
0 0
1,650
1, 675
179
59
0 0
3,650
3,700
556
549
424
425
422
502
302
302
182
82
0
0 0
1, 675
1, 700
184
64
0 0
8,700
3,760
666
558
434
432
481
511
311
311
191
71
0
0 0
1,700
1,725
188
68
0 0
3, 750
6,800
676
567
443
441
440
820
320
520
200
80
0
0 0
1, 725
1, 760
193
73
0 0
3,800
3,850
685
577
463
451
449
529
329
329
809
89
0
0 0
1,750
1,775
197
77
0 0
3,850
8,900
595
586
463
400
458
838
838
388
218
98
0
0 0
1 ,775
1,800
202
82
0 0
8,900
8,950
605
696
473
470
467
347
847
347
227
107
0
0 0
1, 800
1, 825
200,
86
0
3,950
4,000
615
605
483
479
476
850
356
356
236
116
0
0 0
1 ,825
1, 850
211
91
0
4,060
4,060
625
615
493
489
485
865
366
365
845
12.5
5
6 0
1 850
1,875
215
95
0
0
4,050
4,100
685
624
503
498
494
374
374
374
254
134
14
0 0
1,876
i,900
820
100
0
0
4,100
4,150
645
684
513
608
503
383
583
383
269
143
28
0 0
1,900
1,920
224
104
0
/t,150
4,200
666
643
523
517
612
392
392
393
272
152
52
0 0
1, 925
(, 960
229
109
0
4,290
4,260
666
668
533
627
621
401
401
401
281
(61
41
0
1, 950
1, 976
889
113
0
4, 250
4, 300
674
66.2
542
636
530
410
416
410
290
176
50
0 0
1, 975
2,000
238
118
0
4,300
4,350
084
671
662
645
639
. 420
419
419
899
179
59
0 0
2, 000
2,026
242
122
2
4, 860
4, 400
694
081
502
555
548
486
43
468
408
188
68
0
0
2, 020
5 060
247
1 27
7
0
4, 400
4, 450
704
690
672
664
657
440
8
487
317
197
77
0 0
2,050
2, 076
251
151
1 0
1
4, 450
4, 500
714
700
582
574
506
450
448
446
536
8061
80
0
0
2,075
2,100
256
186
10
0
4, 500
4,650
724
709
602
585
576
460
46
455
935
815
95
0
0
0
2,100
2,125
260
140
0
20
4,550
4,600
734
719
602
593
584
470
7
464
144
224
104
0
-
2,126
2,150
265
146
25
0
4,600
4,060
744
728
612
602
593
480
476
475
8,58
219
1I3
0 0
2,160
2,175
209
1 49
29
0
4,650
4,700
754
738
622
612
602
490
.486
482
962
242
122
2 0
2,176
2, 200
274
154
0
34
4,700
4,750
764
747
632
621
611
500
4
96
491
371
251
181
11 0
2,200
2, 225
278
158
.88
4, 750
4, 800
77,9
756
641
630
620
509
504
500
180
260
160
20 0
2,225
2, 250
285
103
43
11
4,800
4,850
783
706
651
640
629
519
614
509
389
269
149
29 0
2
250
.8, 275
287
167
47
4,860
4,900
793
776
661
649
638
629
628
618
498
278
158
.38 0
,
2
275
300
8
992
(72
0
02
4,900
4,950
803
785
671
659
647
539
633
527
987
887
197
47 0
"
,
2, 300
,
2, 325
296
170
56
0
4,950
6,000
813
794
681
668
656
649
64
556
416
296
176
56 0
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And the Senate agree to the same.
Amendment numbered 4:
That the House recede from its disagreement to the amendment of
the Senate numbered 4, and agree to the same with an amendment as
follows:
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following:
" (b) IMPOSITION OF TAx.---There shall be levied, collected, and paid
for each taxable year upon the normal-tax net income of every corporation
(except a corporation subject to a tax imposed by section 231 (a), Supple-
ment 0, or Supplement Q)-
(1) CALENDAR YEAR 1961.-In the case of a taxable year
beginning on January 1, 1951, and ending on December 31, 1951,
a tax of 28% per cent urn of the normal-tax net income.
" (2) TAXABLE YEARS BEGINNING AFTER MARCH 31, 1961, AND
BEFORE APRIL 1, 1954.-In the case of taxable. years beginning
after March 31, 1951, and before April 1, 1954, a tax of 30 per
centum of the normal-tax income.
" (3) TAXABLE YEARS BEGINNING AFTER MARCH 31, 1954.--In
the case of taxable years beginning after March 31, 1954, a tax of
25 per centum of the normal-tax net income."
And the Senate agree to the same.
Amendment numbered 6:
That the House recede from its disagreement to the amendment of
the Senate numbered 6, and agreed to the same with the following
amendments:
On page 13, line 13, of the Senate engrossed amendments, strike
our "(c)" and insert (b).
On page 13, line 24, of the Senate engrossed amendments strike out
"16%" and insert 17%.
On page 14, line 12, of the Senate engrossed amendments strike out
"17" and insert 18.
And. the Senate agree to the same.
Amendment numbered 7:
That the House recede from its disagreement to the amendment of
the Senate numbered 7, and agree to the same with an amendment as
follows:
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following:
(C) MUTUAL INSURANCE COMPANIES OTHER' THAN LIFE OR
MARINE.-
(1) Section 207 (a) (1) (relating to normal tax and surtax on
mutual insurance companies, other than life or marine) is hereby
amended by striking out subparagraphs (A) and (B) and inserting
in lieu thereof the following:
"(A) Taxable Years Beginning After December 81, 1950,
and Before April 1, 1951.In the case of taxable years beginning
after December 31, 1950, and before April 1, 1951, and ending
after March 31, 1951-
"(i) Normal tax. -A normal tax of 28% per centum of
the normal-tax net income, or 57% per centum of the amount
Al~
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REVENUE ACT OF 1951 7
by which the normal-tax net income exceeds $3,000, which-
ever is the lesser; plus
"(ii) Surtax.-.A surtax of 22 per centum of the corpora-
tion surtax net income in excess of $25,000.
"(B) Taxable Years Beginning After March 31, 1951, and
Before April 1, 1954. In the case of taxable years beginning
after March 81, 1951, and before April 1, 1954-
" (i) Normal tax.-A normal tax of 30 per eentum of the
normal-tax net income, or 60 per centum of the amount by
which the normal-tax net income exceeds $3,000, whichever
is the lesser; plus
" (ii) Surtax.-A surtax of 22 per centum of the corpora-
tion surtax net income in excess of $25,000.
" (C) Taxable Years Beginning After March 31, 1954.-
In the case of a taxable year beginning after March 31, 1954-
" (i) Normal tax.-A normal tax of 25 per centum of the
normal-tax net income, or 50 per centum of the amount by
which the normal-tax net income exceeds $3,000, whichever
is the lesser; plus
" (ii) Surtax.-A surtax of 22 per centum of the corpora-
tion surtax net income in excess of $25,000."
(2) Section 207 (a) (3) (relating to a normal tax and surtax on
interinsurers and reciprocal underwriters) is hereby amended by
striking out subparagraphs (A) and (B) and inserting in lieu thereof
the following:
"(A) Taxable Years Beginning After December 31, 1950,
and before April 1, 1951.-In the case of taxable years begin-
ning after December 31, 1950, and before April 1, 1951, and
ending after March 31, 1951-
"(i) Normal tax.-A normal tax of 28% per centum of
the normal-tax net income, or 57/ per centum of the
amount by which the normal-tax net income exceeds
$50,000, whichever is the lesser; plus
"(ii) Surtax.-A surtax of 22 per centum of the corpo-
ration surtax net income in excess of $25,000, or 33 per
centum of the amount by which the corporation surtax net
income exceeds $50,000, whichever is the lesser.
"(B) Taxable Years Beginning After March 31, 1951, and
Before April 1, 1954.-In the case of taxable years beginning
after March 31, 1951, and before April 1, 1954-
"(i) Normal tax.-A normal tax of 30 per centum of
the normal-tax net income, or 60 per centum of the amount
by which the normal-tax net income exceeds $50,000,
whichever is the lesser; plus
" (ii) Surtax.-A surtax of 22 per centum of the corpo-
ration surtax net income in excess of $25,000, or 33 per
centum of ' the amount by which the corporation surtax net
income exceeds $50,000, whichever is the lesser.
" (C) Taxable Years Beginning After March 31, 1954.-In
the case of a taxable year beginning after March 31, 1954-
" (i) Normal tax.-A normal tax of 25 per centum of the
normal-tax net income, or 50 per centum of the amount
by which the normal-tax net income exceeds $50,000,
whichever is the lesser; plus
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"(ii) Surtax.-A surtax of 22 per centum of the corpora-
tion surtax net income in excess of $25,000, or 33 per
centum of the amount by which the corporation surtax net
income exceeds $50,000, whichever is the lesser."
(d) REGULATED INVESTMENT COMPANIES.-Section 862 (b) (relating
to tax on regulated investment companies) is hereby amended by striking
out paragraphs (3) and (4) and inserting in lieu thereof the following:
" (3) In the case of taxable years beginning after December 81,
1950, and before April 1, 1951, and ending after March 31, 1951,
there shall be levied, collected, and paid for each taxably, year upon
its Supplement Q net income a tax equal to 28% per centum of the
amount thereof. In the case of taxable years beginning after March
31, 1951, and before April 1, 1954, there shall be levied, collected,
and paid for each taxable year upon its Supplement Q net income a
tax equal to 30 per centum of the amount thereof. In the case of
taxable years beginning after March 31, 1954, there shall be levied,
collected, and paid for each taxable year upon its Supplement Q
net income a tax equal to 25 per centum of the amount thereof.
" (4) In the case of taxable years beginning after December 31,
1950, there shall be levied, collected, and paid for each taxable year
upon its Supplement Q surtax net income a tax equal to 22 per
centum of the amount thereof in excess of $25,000."
(e) BUSINESS INCOME OF CERTAIN SECTION 101 ORGANIZATIONS.-
Section 421 (a) (1) (relating to imposition of tax on business income of
certain section 101 organizations) is hereby amended by inserting before
the period at the end thereof the following: "; except that (A) in the case
of taxable years beginning before April 1, 1951, and ending after March
31, 1951, the normal tax shall be 28% per centum of the Supplement U
net income, and. (B) in the case of taxable years beginning after March
31, 1951, and before April 1, 1954, the normal tax shall be 30 per centum
of the Supplement U net income".
(f) AMENDMENT OF SECTION 15.-Section 15 (relating to surtax on
corporations) is hereby amended to read. as follows:
"SEC. 15. SURTAX ON CORPORATIONS.
"(a) CORPORATION SURTAX NET INCOME.--For the purposes of this
chapter, the term `corporation surtax net income' means the net income
minus the sum of the .following credits:
" (1) The credit for dividends received provided in section 26 (b);
" (2) In the case of a public utility, the credit for dividends paid
on its preferred stock provided in section 26 (h);
" (3) In the case of a western hemisphere trade corporation (as
defined in section 109), the credit provided in section 26 (i).
" (b) IMPOSITION OF TAx.- There shall be levied, collected, and paid
for each taxable year upon the corporation surtax net income o=f every
corporation (except a corporation subject to a tax imposed by section 231
(a), Supplement 0, or Supplement 9) a surtax of 22 per centum of the
amount of the corporation surtax net income in excess of $25,000.
" (c) DISALLOWANCE OF SURTAX EXEMPTION AND MINIMUM EXCESS
PROFITS CREDIT.-If any corporation transfers, on or after January
1, 1951, all or part of its property (other than money) to another corpora-
tion which was created for the purpose of acquiring such property or
which was not actively engaged in business at the time of such acquisition,
and if after such transfer the transferor corporation or its stockholders,
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REVENUE ACT OF 1951 9
or both, are in control of such transferee corporation during any part of
the taxable year of such transferee corporation, then such transferee cor-
poration shall not for such taxable year (except as may be otherwise
determined under section 129 (b)) be allowed either the $25,000 exemption
from surtax provided in subsection (b) or the $25,000 minimum excess
profits credit provided in the last sentence of section 431, unless such
transferee corporation shall establish by the clear preponderance of the
evidence that the securing of such exemption or credit was not a major
purpose of such transfer. For the purposes of this subsection, control
means the ownership of stock possessing at least 80 per centum of the
total combined voting power of all classes o f stock entitled to vote or at
least 80 per centum of the total value of shares of all classes of stock of
the corporation. In determining the ownership of stock for the purpose
of this subsection, the ownership of stock shall be determined in accord-
ance with the provisions of section 503, except that constructive ownership
under section 503 (a) (2) shall be determined only with respect to the
individual's spouse and minor children. The provisions of section 129 (b),
and the authority of the Secretary under such section, shall, to the extent
not inconsistent with the provisions of this subsection, be applicable to
this subsection. This subsection shall not apply to any taxable year
with respect to which the tax imposed by subchapter D of this chapter is
not in effect."
(g) TECHNICAL AMENDMENT.-Section 14 (relating to normal tax
on special classes of corporations in the case of taxable years beginning
before July 1, 1950) is hereby repealed.
And the Senate agree to the same.
Amendment numbered 8:
That the House recede from its disagreement to the amendment of
the Senate numbered 8, and agree to the same with an amendment
as follows:
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following:
SEC. 122. CREDITS OF CORPORATIONS.
(a) DIVIDENDS RECEIVED CREDIT.--Paragraphs (1) and (2) of sec=
tion 26 (b) (relating to credit for dividends received) are hereby amended
to read as follows:
" (1) IN GENERAL.-85 per centum of the amount received as
dividends (other than dividends described in paragraph (2) on the
preferred stock of a public utility) from a domestic corporation which
is subject to taxation under this chapter.
" (2) CERTAIN PREFERRED STOCK.-
"(A) Calendar Year 1951.-In the case of a taxable year
beginning on January 1, 1951, and ending on December 31,
1951, 61 per centum of the amount received as dividends on the
preferred stock of a public utility which is subject to taxation
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under this chapter and with respect to which the credit provided
in section 26 (h) for dividends paid is allowable.
"(B) Taxable Years Beginning After March 31, 1951, and
Before April 1, 1954. -In the case of taxable years beginning
after March 31, 1951, and before April 1, 1954, 62 per centum
of the amount received as dividends.on the preferred stock of a
public utility which is subject to taxation under this chapter and
with respect to which the credit provided in section 26 (h) for
dividends paid is allowable.
"(C) Taxable Years Beginning After March 31, 1954. -In
the case of taxable years beginning after March 31, 1954, 59
per centum of the amount received as dividends on the preferred
stock of a public utility which is subject to taxation under this
chapter and with respect to which the credit provided in section
26 (h) for dividends paid is allowable."
(b) CREDIT FOR DIVIDENDS PAID ON CERTAIN PREFERRED STOCK.--
The first sentence of section 26 (h) (1) (relating to amount of credit for
dividends paid on certain preferred stock) is hereby amended to read as
follows: "In the case of a public utility, (A) for a taxable year beginning
on January 1, 1951, and ending on December 31, 1951, an amount
equal to 28 per centum of the lesser of (i) the amount of dividends paid
during the taxable year on its preferred stock or (ii) the adjusted net
income for such taxable year minus the credit for dividends received
provided in subsection (b) for such year,, (B) for a taxable year beginning
after March 31, 1951 and before April 1, 1954, an amount equal to
27 per centum of the lesser of '(i) the amount of dividends paid during
the taxable year on its preferred stock or (ii) the adjusted net income for
such taxable year minus the credit for dividends received provided in
subsection (b) for such year, and (C) for a taxable year beginning after
March 31, 1954, an amount equal to 30 per centum of the lower of (i) the
amount of dividends paid during the taxable year on its preferred stock or
(ii) the adjusted net income for such taxable year minus the credit for
dividends received provided in subsection (b) for such year."
(C) WESTERN HEMISPHERE TRADE CORPORATIONS.-Section 26 (i)
(relating to credit of a western hemisphere trade corporation) is hereby
amended to read as follows:
" (i) WESTERN HEMISPHERE TRADE CORPORATIONS.-In the case of
a western hemisphere trade corporation (as defined in section 109)-
" (1) CALENDAR YEAR 1961.-In the case of a taxable year
beginning on January 1, 1951, and ending on December 31, 1951,
an amount equal to 28 per centum of its normal-tax net income com-
puted without regard to the credit provided in this subsection.
"(2) TAXABLE YEARS BEGINNING AFTER MARCH 31, 1951, AND
BEFORE APRIL 1, 1954-In the case of a taxable year beginning
after March 31, 1951, and before April 1, 1954, an amount equal.
to 27 per centum of its normal-tax net income computed without
regard to the credit provided in this subsection.
" (3) TAXABLE YEARS BEGINNING AFTER MARCH 31, 1954.--In
the case of a taxable year beginning after March 31, 1954, an
amount equal to 30 per centum of its normal-tax net income computed
without regard to the credit provided in this subsection."
And the Senate agree to the same.
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REVENUE ACT OF 1951 11
Amendment numbered 13:
That the Mouse recede from its disagreement to the amendment of
the Senate numbered 13, and agree to the same with the following
amendments:
On page 27 of the Senate engrossed amendments strike out lines 1
to 5, inclusive, and insert in lieu thereof the following:
"(3) that portion of a tentative tax consisting of-
"(A) a tentative normal tax of 30 per centum of the normal-
tax net income, plus
"(B) a tentative surtax of 20 per centum of the surtax net in-
come in excess of $25,000,
On page 31 of the Senate engrossed amendments strike out subsec-
tion (k) and insert in lieu thereof the following:
" (ic) TAXABLE YEARS OF, CORPORATIONS BEGINNING BEFORE APRIL
1, 1954, AND ENDING AFTER MARCH 31, 1954.-In the ease of a tax-
able year Q f a corporation beginning before April 1, 1954, and ending
after March 31, 1954, the tax imposed sections 13 and 15, or section
421 (a) (1), shall be an amount equal to the sum of-
"(1) that portion of a tentative tax, computed under the pro-
visions of sections 13 and 15, or section 421 (a) (1), applicable to
years beginning on January 1, 1953, which the number of days in
such taxable year prior to April 1, 1954, bears to the total number
of days in such taxable year, plus
"(2) that portion of a tentative tax, computed under the provisions
of sections 13 and 15, or section 421 (a) (1), applicable to years
beginning on April 1, 1954, as if such provisions were applicable
to such taxable year, which the number of days in such taxable year
after March 31, 1954, bears to the total number of days in such
taxable year."
And the Senate agree to the same.
Amendment numbered 28:
That the House recede from its disagreement to the amendment of
the Senate numbered 28, and agree to the same with the following
amendments:
Strike out the surtax table beginning on page 39 of the Senate
engrossed amendments and insert the following:
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"If the surtax net income is:
Not over $2,000___________________
19.3% of the surtax net income.
Over $2,000 but not over $/,000______
$386, plus 20.4% of excess over $2,000.
Over $4,000 but not over $6,000-_____
$794, plus 24% of excess over $4,000.
Over $6,000 but not over $8,000-_____
$1,274, plus 26% of excess over $6,000.
Over $8,000 but not over $10,000_____
$1,794, plus 31 % of excess over $8,000.
Over $10,000 but not over $12,000____
$2,444, plus 32% of excess over $10.000.
Over $12,000 but not over $14,000__-_
$3,054, plus 38% of excess over $12,000.
Over $14,000 but not over $16,000__-_
$3,814, plus 41 % of excess over $14,000.
Over $16,000. but not over $18,000____
$4,634, plus 44%of excess over $16,000.
Over $18,000 but not over $20,000____
$5,514, plus 45% of excess over $18,000.
Over $20,000 but not over $22,000____
$6,414, plus 49 % of excess over $20.000.
Over $22,000 but not over $24,000____
$7,394, plus 51 % of excess over $22,000.
Over $24,000 but not over $28,000____
$8,414, plus 54% of excess over $24,000.
Over $28,000 but not over $32,000____
$10,574, plus 57% of excess over
$28,000.
Over $32,000 but not over $38,000____
$12,854, plus 60% of excess over
$32,000.
Over $38,000 but not over $44,000_..__
$16,454, plus 63% of excess over
$38,000.
Over $44,000 but not over $50,000____
$20,234, plus 68% of excess over
$44,000.
Over $50,000 but not over $60,000____
$24,314, plus 69% of excess over
$50,000.
Over $60,000 but not over $70,000____
$31,214, plus 70% of excess over
$60,000.
Over $70,000 but. not over $80,000____
$38,214, plus 74% of excess over
$70,000.
Over $80,000 but not over $90,000__._
$45,614, plus 76% of excess over
$80,000.
Over $90,000 but not over $100,000___
$53,214, plus 78% of excess over
$90,000.
Over $100,000 but not over $150,000__
$61,014, plus 82% of excess over
$100,000.
Over $150,000 but not over $200,000._
$102,014, plus 85% of excess over
$150,000.
Over $200,000 but not over $300,000__
$144,514, plus 88% of excess over
Over $300,000_______________-____
$200,000.
$232,514, plus 89% of excess over
$300,000.
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REVENUE ACT :OF 1951 13
Strike out the surtax table beginning on page 41 of the Senate
engrossed amendments and insert the following:
"If the surtax net income is:
The surtax shall be:
Not over $2,000___________________
17% of the surtax net income.
Over $2,000 but not over $4,000______
$340, plus 18% of excess over $2,000.
Over $4,000 but not over $6,000______
$700, plus 21 % of excess over $4,000:
Over $6,000 but not over $8,000______
$1,120, plus 23% of excess over $6,000.
Over $8,000 but not over $10,000_____
$1,580, plus 27% of excess over $8,000.
Over $10;000 but not over $12,000____
$2,120, plus 29% of excess over $10,000.
Over $12,000 but not over $14,000____
$2,700, plus 33% of excess over $12,000.
Over $14,000 but not over $16,000____
$3,360, plus 36% of excess over $14,000.
Over $16,000 but not over $18,000____
$4,080, plus 39 % of excess over $16,000.
Over $18,000 but not over $20,000____
$4,860, plus 40% of excess over $18,000:
Over $20,000 but not over $22,000____
$5,660, plus 44% of excess over $20,000.
Over $22,000 but not over $24,000____
$6,540, plus 46 % of excess over $22,000.
Over $24,000 but not over $28,000____
$7,460, plus 49% of excess over $24,000.
Over $28,000 but not over $32,000____
$9,420, plus 51 % of excess over $28,000.
Over $32,000 but not over $38,000____
$11,460, plus 55% of excess over
$32,000.
Over $38,000 but not over $44,000____
$14,760, plus 59% of excess over
$38,000.
Over $44,000 but not over $50,000____
$18,300, plus 63% of excess over
$44,000.
Over $60,000 but not over $60,000__--
$22,080, plus 65% of excess over
$50,000.
Over $60,000 but not over $70,000____
$28,680, plus 68% of excess over
$60,000.
Over $70,000 but not over $80,000____
$35,380, plus 71% of excess over
$70,000.
Over $80,000 but not over $90,000 ----
$42,480, plus 73% of excess over
$80,000.
Over $90,000 but not over $100,000___
$49,780, plus 77% of excess over
$90,000.
000 but not over $150
000__
Over $100
plus 80% of excess over
$57
480
,
,
,
,
$100,000.
Over $150,000 but not over $200,000__
$97,480, plus 84% of excess over
$150,000.
Over $900,000 but not over $300,000__
$139,480, plus 87% of excess over
$200,000.
Over $300,000___________________
$226,480, plus 88% of excess over
$300,000.
And the Senate agree to the same.
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Amendment numbered 43:
That the House recede from its disagreement to the amendment of
the Senate numbered 43, and agree to the same with an amendment
as follows:
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following:
SEC. 311. CREDIT FOR DIVIDENDS RECEIVED.
(a) DIVIDENDS FROM FOREIGN CORPORATION ENGAGED IN TRADE
OR BUSINESS IN THE UNITED STATES.-Section 26 (b) (relating to
dividends received credit) is hereby amended by inserting after paragraph
(2) the following new paragraph:
"(3) DIVIDENDS RECEIVED FROM CERTAIN FOREIGN CORPORA-
TIONS.-In the case of dividends received from a foreign corporation
(other than a foreign personal holding company) which is subject to
taxation under this chapter, if, for an uninterrupted period of not
less than 36 months ending with the close of such foreign. corpora-
tion's taxable year in which such dividends are paid (or, if .the cor-
poration has not been in existence for 36 months at the close of such
taxable year, for the period the foreign corporation has been in exist-
ence as of the close of such taxable year) such foreign corporation has
been engaged in trade or business within the United States and has
derived 50 per centum or more of its gross income from sources within
the United States-
"(A) an amount equal to 85 per centum of the dividends
received out of its earnings or profits specified in clause (2) of
the first sentence of section 115 (a), but such amount shall not
exceed an amount which bears the same ratio to 85 per centum
of such dividends received out. of such earnings or profits as
the gross income of such foreign corporation for the taxable year
from sources within the United States bears to its gross income
from all sources for such taxable year, and
"(B) an amount equal to 85 per centum of the dividends
received out of that part of its earnings or profits specified in
clause (1) of therfirst sentence of section 115 (a) accumulated
after the beginning of such uninterrupted period, but such
amount shall not exceed an amount which bears the same ratio
to 85 per centum of such dividends received out of such accumu-
lated earnings or profits as the gross income of such foreign
corporation from sources within the United States for the portion
of such uninterrupted period ending at the beginning of such
taxable year bears to its gross income from all sources for such
portion of such uninterrupted period.
For determination of earnings or profits distributed in any taxable
year, see section 115 (b)."
(b) TECHNICAL AMENDMENT.--Section 119 (a) (2) (B) (relating
to rules as to source of income in the case of dividends) is hereby amended
by inserting before the semicolon at the end thereof the following: "to
the extent exceeding the amount which is 100/85ths of the amount of the
credit allowable under section 26 (b) in respect of such dividends".
1; (c) EFFECTIVE DATE.-The amendments made by this section shall
be applicable only with respect to taxable years beginning after December
31, 1950.
And the Senate agree to the same.
Aft
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REVENUE ACT OF 1951 15
" (I) Credit unions without capital stock organized and operated
for mutual purposes and without profit; and corporations or
associations without capital stock organized prior to September
1, 1951, and operated for mutual purposes and without profit for
the purpose of providing reserve funds for, and insurance of, shares
or deposits in-
" (A) domestic building and loan associations,
" (B) cooperative banks without capital stock organized and
operated for mutual purposes and without profit, or
" (C) mutual savings banks not having capital stock repre-
sented by shares;".
Amendment numbered 45:
That the House recede from its disagreement to the amendment of
the Senate numbered 45, and agree to the same with an amendment
as follows:
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following:
SEC. 313. MUTUAL SAVINGS BANKS, BUILDING AND LOAN
ASSOCIATIONS, COOPERATIVE BANKS.
(a) MUTUAL SAVINGS BANKS.-Section 101 (2) (relating to exemption
from tax of mutual savings banks) is hereby repealed.
(b) BUILDING AND LOAN ASSOCIATIONS AND COOPERATIVE BANKS.-
Section 101 (4) (relating to exemption from tax of building and loan
associations and cooperative banks) is hereby amended to read as follows:
(c) EXEMPTIONS FROM EXCESS PROFITS TAX. -Section 454 (corpora-
tions exempt from the excess profits tax) ' is hereby amended by adding at
the end thereof the following:
"(h) Any mutual savings bank not having capital stock represented by
shares, any domestic building and loan association (as defined in section
8797 (a) (19)), and any cooperative bank without capital stock organized
and operated for mutual purposes and without profit."
(d) FEDERAL SAVINGS AND LOAN ASSOCIATIONS.-Section 5 (h) of
the Home Owners' Loan Act -of 1933, as amended (12 U. S. C. 1464 (h)),
is hereby amended by striking out "date)" and inserting in lieu thereof
the following: "date, and except, in the case of taxable years beginning
after December 31, 1951, income, war-profits, and excess-profits taxes)".
(e) BAD DEBT RESERVES.-Section 23 (k) (1) (relating to deduction
from gross income of bad debts) is hereby amended by adding at the end
thereof the following: "In the case of a mutual savings bank not having
capital stock represented by shares, a domestic building and loan associa-
tion, and a cooperative bank without capital stock organized and operated
for mutual purposes and without profit, the reasonable addition to a
reserve for bad debts shall be determined with due regard to the amount
of the taxpayer's surplus or bad debt reserves existing at the close of
December 31, 1951. In the'case of a taxpayer described in the preceding
sentence, the reasonable addition to a reserve for bad debts for any taxable
year shall in no case be less than the amount determined by the taxpayer
as the reasonable addition for such year; except that the amount deter-
mined by the taxpayer under this sentence shall not be greater than the
lesser of (A) the amount of its net income for the taxable year, computed
without regard to this subsection, or (B) the amount by which 12 per
centum of the total deposits or withdrawable accounts of its depositors
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16 REVENUE ACT OF 1951
at the close of such year exceeds :the sum of its surplus, undivided profits?
and reserves at the beginning of the taxable year."
(f) DIVIDENDS PAID TO DEPOSITORS. --Section 23 (r) (relating to
the deduction from gross income of certain dividends paid by banking
corporations) is hereby amended to read as follows:
" (r) DIVIDENDS PAID BY BANKING CORPORATIONS.-
"(1) In the. case of mutual savings banks, cooperative banks, and
domestic building and loan associations, amounts paid to, or credited
to the accounts of, depositors or holders of accounts as dividends on
their deposits or withdrawable accounts, if such amounts paid or
credited are withdrawable on demand subject only to customary
notice of intention to withdraw.
"(2) For deduction of dividends paid by certain other banking
corporations, see section 121."
(g) DEDUCTION FOR REPAYMENT OF CERTAIN LOANS.--Section 23
(relating to deductions from gross income) is hereby amended by adding
at the end thereof the following:
" (dd) REPAYMENT BY MUTUAL SAVINGS BANKS, ETC., OF CERTAIN
LOANS.-In the case of a mutual savings bank not having capital stock
represented by shares, a domestic building and loan association, or a
cooperative bank without capital stock organized and operated for mutual
purposes and without profit, amounts paid by the taxpayer during the
taxable year in repayment of loans made prior to September 1, 1951, by
(1) the United States or any agency or instrumentality thereof which is
wholly owned by the hnited States, or (2) any mutual fund established
under the authority of the laws of any State."
(h) DEFINITION VF BANK. -Section 104. (a) (relating to definition of
bank) is hereby amended by inserting at the end thereof the following:
"Such term also means a domestic building and loan association."
(2) DEFINITION OF DOMESTIC BUILDING AND LOAN ASSOCIATION.-
Section 3797 (a) (relating to definitions for the purposes of the Internal
Revenue Code) is.hereby amended by adding at the end thereof the following
new paragraph: ,
" (19) DOMESTIC BUILDING AND LOAN ASSOCIATION. -The term
`domestic building and loan association' means a domestic building
and loan association, a domestic savings and loan association, and a
Federal savings and loan association, substantially all the business
of which is confined to making loans to members."
(j) EFFECTIVE DATE.-The amendments made by this section shall
be applicable only urith respect to taxable years beginning after.De-
cember 31, 1951.
And the Senate agree to the same.
Amendment numbered 46:
That the House recede from its disagreement to the amendment of
the Senate numbered 46, and agree to the same with the following
amendments :
On page 67, line 8, of the Senate engrossed amendments, insert
after the period the following: Allocations made after the close of the
taxable year and on or before the fifteenth day of the ninth month following
the close of such year shall be considered as made on the last day of such
taxable year to the extent the allocations are attributable to income derived
before the close of such year.
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REVENUE ACT OF 1951 17
On page 67, line 10, of the Senate engrossed amendments, insert
after "patronage" the following : in the same or preceding years
On page 69 of the Senate engrossed amendments strike out line 1
and all that follows through line 9.
. On page 69, line 10, of the Senate engrossed amendments, strike
out "(e)" and insert (d)
And the Senate-agree to the same.
Amendment numbered 53:
That the House recede from its disagreement to the amendment of
the Senate numbered 53, and agree to the same with an amendment as
follows:
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following
"(i) in the case of sand, gravel, slate, stone (including
pumice and scoria), brick and tile clay, shale, oyster shell,
clam shell, granite, marble, sodium chloride, and, if from
brine wells, calcium chloride, magnesium chloride, and
bromine, 5 per centum,
"(ii) in the case of coal, asbestos, brucite, dolomite,
magnesite, perlite, wollastonite, calcium carbonates, and
magnesium carbonates, 10 per centum,
"(iii) in the case of metal mines, aplite, bauxite,
fluorspar, flake graphite, vermiculite, beryl, garnet, feld-
spar, mica, talc (including pyrophyllite), lepidolite,
spodumene, barite, ball clay, sagger clay, china clay,
phosphate rock, rock asphalt, trona, bentonite, gilsonite,
thenardite, borax, fuller's earth, tripoli, refractory and
fire clay, quartzite, diatomaceous earth, metallurgical grade
limestone, chemical grade limestone, and potash, 15 per
centum, and
And the Senate agree to the same.
Amendment numbered 54:
That the House recede from its disagreement to the amendment of
the Senate numbered 54, and agree to the same with an amendment
as follows:
On page 74 of the Senate engrossed amendments strike out lines
12 and 13 and insert the following: taxes) is hereby amended by striking
out "50 per centum of the value of the net estate" and inserting in lieu
thereof "35 per centum of the value of the gross estate".; and the Senate
agree to the same.
Amendment numbered 55:
That the House recede from its disagreement to the amendment of
the Senate numbered 55, and agree to the same with an amendment
as follows:
On page 74, line 21, of the Senate engrossed amendments strike out
"EXCLUSIVE" and insert EXCLUSION; and the Senate agree to the
same.
Amendment numbered 64:
That the House recede from its disagreement to the amendment of
the Senate numbered 64, and agree to the same with an amendment as
follows:
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-On page 79 of the Senate engrossed amendments strike out all after
"poultry" in line 14 to and including "acquisition" in line 17; and
the Senate agree to the same.
Amendment numbered 67:
That the House recede from its disagreement to the amendment of
the Senate numbered 67, and agree to the same with an amendment
as follows:
On page 80, lines 7 and 8, of the Senate engrossed amendments,
strike out the following: "in the cutting of such timber or"; and the
Senate agree to the same. -
Amendment numbered 77:
That the House recede from its disagreement to the amendment of
the Senate numbered 77, and agree to the same with an amendment as
follows:
Strike out the matter proposed to be stricken out by the Senate
amendment and insert the following:
SEC. 328. TREATMENT OF GAIN ON SALES OF CERTAIN
PROPERTY BETWEEN SPOUSES AND BETWEEN
AN INDIVIDUAL AND A CONTROLLED COR-
PORATION.
(a) DISALLOWANCE OF CAPITAL GAIN TREATMENT.-Section 117
(relating to capital gains and losses) is hereby amended by adding at the
end thereof the following new subsection:
"(o) GAIN FROM SALE OF CERTAIN PROPERTY BETWEEN SPOUSES
OR BETWEEN AN INDIVIDUAL AND A CONTROLLED CORPORATION.-
"(1) TREATMENT OF GAIN AS ORDINARY INCOME.-In the case
of a sale or exchange, directly or indirectly, of property described in
paragraph (2)-
"(A) between a husband and wife; or
"(B) between an individual and a corporation more than 80
per centum in value of the outstanding stock of. which is owned
by such individual, his spouse, and his minor children and
minor grandchildren;
any gain recognized to the transferor from the sale or exchange of
such property shall be considered as gain from the sale or exchange
of property which is neither a capital asset nor property described in
subsection (j).
"(2) SUBSECTION APPLICABLE ONLY TO SALES OR EXCHANGES
OF DEPRECIABLE PROPERTY.-This subsection shall apply only
in the case of a sale or exchange of property by a transferor which in
the hands of the transferee is property of a character which is subject
to the allowance for depreciation provided in section 23 (1)."
(b) EFFECTIVE DATE.-The amendment made by subsection (a)
shall be applicable with respect to taxable years ending after April 80,
1961, but shall apply only with respect to sales or exchanges; made after
May 3, 1951.
And the Senate agree to the same.
Amendment numbered 78:
That the House recede from its disagreement to the amendment of
the Senate numbered 78, and agree to the same with the following
amendments :
On page 83, line 4, of the Senate engrossed amendments, strike
out "328" and insert 329
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On page 83, line 10, of the Senate engrossed amendments, strike
out "(o)" and insert (p)
And the Senate agree to the same.
Amendment numbered 79:
That the House recede from its disagreement to the amendment of
the Senate numbered 79, and agree to the same with an amendment
as follows:
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following:
SEC. 330. NET OPERATING LOSS CARRY-OVER.
(a) LOSS FOR TAXABLE YEAR BEGINNING BEFORE 1948.-Section
122 (b) (2) (A) (relating to the amount of carry-overs) is hereby amended
by striking out "1950", wherever it appears therein, and inserting in lieu
thereof "1948".
(b) ALLOWANCE OF THREE-YEAR Loss CARRY-OVER FROM TAXABLE
YEARS 1948-1949.-Section 122 (b) (2) (relating to the amount of
carry-over) is hereby amended by adding after subparagraph (B) the
following new subparagraph:
"(C) Loss for Taxable Year Beginning After December 31, 1947,
and Before January 1, 1950.-If for any taxable year beginning
after December 31, 1947, and before January 1, 1950, the taxpayer
has a net operating loss, such net operating loss shall be a net oper-
ating loss carry-over for each of the three succeeding taxable years,
except that the carry-over in the case of each such succeeding taxable
year (other than the first succeeding taxable year) shall be the excess,
if any, of the amount of such net operating loss over the sum of the
net income for each of the intervening years computed-
"(i) with the exceptions, additions, and limitations provided
in subsection (d) (1), (2), (4), and (6), and
"(ii) by determining the net operating loss deduction for each
intervening taxable year without regard to such net operating
loss or to the net operating loss for any succeeding taxable year
and without regard to any reduction specified in subsection (c).
For the purpose of the preceding sentence, the net operating loss for
any taxable year beginning after December 31, 1947, and before
January 1, 1950, shall be reduced by the sum of the net income for
each of the two preceding taxable years computed-
"(iii) with the exceptions, additions, and limitations pro-
vided in subsection (d) (1), (2), (4), and (6), and
"(iv) by determining the net operating loss deduction without
regard to such net operating loss or to the net operating loss for
the succeeding taxable year, and without regard to any reduction
specified in subsection (c)."
(c) EFFECTIVE DATE.-The amendments made by this section shall be
applicable in computing the net operating loss deduction for taxable
years beginning after December 31, 1948.
And the Senate agree to the same.
Amendment numbered 80:
That the House recede from its disagreement to the amendment of
the Senate numbered 80, and agree to the same with an amendment
as follows:
On page 87, line 17, of the Senate engrossed amendments, strike
out "330" and insert '331; and the Senate agree to the same.
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20 REVENUE ACT OF 1951
Amendment numbered 81:
That the House recede from its disagreement; to the amendment of
the Senate numbered 81, and agree to the same with the following
amendments:
On page 88, line 7, of the Senate engrossed amendments, strike out
"331" and insert .332
On page 88, line 21, of the Senate engrossed amendments, strike
out "a majority" and insert the following: 60 per centum or more
And the Senate agree to the same.
Amendment numbered 82:
That the House recede from its disagreement to the amendment of
the Senate numbered 82, and agree to the same with an amendment
as follows:
On page 89, line 5, of the Senate engrossed amendments, strike
out "332" and insert 333; and the Senate agree to the same.
Amendment numbered 83:
That the House recede from its disagreement to the amendment of
the Senate numbered 83, and agree to the same with an amendment
as follows:
On page 89, line 19, of the Senate engrossed amendments, strike
out "333" and insert 334; and the Senate agree to the same.
Amendment numbered 84:
That the House recede from its disagreement to the amendment of
the Senate numbered 84, and agree to the same with the following
amendments :
On page 90, line 22, of the Senate engrossed amendments, strike
out "334" and insert 335
On page 91 of the Senate, engrossed amendments strike out line
14 and insert the following: coupons or in registered form, and the
term `securities of the employer corporation' includes securities of a
parent or subsidiary corporation (as defined in section 130A (d) (2) and
(3)) of the employer corporation."; and the Senate agree to the same,
Amendment numbered 85:
That the House recede from its disagreement to the amendment of
the Senate numbered 85, and agree to the same with an amendment
as follows :
On page 91, line 20, of the Senate engrossed amendments, strike
out "335" and insert 336; and the Senate agree to the same.
Amendment numbered 86 :
That the House recede from its disagreement to the amendment of
the Senate numbered 86, and,agree to the same with an amendment
as follows:
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following: 337; and the Senate agree to the same.
Amendment numbered 88:
That the House recede from its disagreement to the amendment of
the Senate numbered 88, and agree to the same with an amendment
as follows:
On page 97, line 4, of the Senate engrossed amendments, strike out
"337" and insert 338; and -the Senate agree to the same.
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REVENUE ACT OF 1951
21
Amendment numbered 89:
That the House recede from its disagreement to the amendment of
the Senate numbered 89, and agree to the same with an amendment
as follows:
On page 98, line 4, of the Senate engrossed amendments, strike out
"3738" and insert 389; and the Senate agree to the same.
Amendment numbered 90:
That the House recede from its disagreement to the amendment of
the Senate numbered 90, and agree to the same with an amendment
as follows:
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following: 340; and the Senate agree to the same.
Amendment numbered 91:
That the House recede from its disagreement to the amendment of
the Senate numbered 91, and agree to the,same with an amendment
s as follows:
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following:
(c) EFFECTIVE DATE.-The amendments made by this section shall be
applicable with respect to taxable years beginning after December 31,
1950. The determination as to whether a person shall be recognized as a
partner for income tax purposes for any taxable year beginning before
January 1, 1951, shall be made as if this section had not been enacted and
without inferences drawn from the fact that this section is not expressly
made applicable with respect to taxable years beginning before January 1,
1951. In applying this subsection where the taxable year of any family
partner is different from the taxable year of the partnership-
(1) if a taxable year of the partnership beginning in 1950 ends
within or with, as to all'of the family partners, taxable years which
begin in 1951, then the amendments made by this section. shall be
applicable with respect to all distributive shares of income derived by
the family partners from such taxable year of the partnership begin-
ning in 1950, and
(2) if a taxable year of the partnership ending in 1951 ends within
or with a taxable year of any family partner which began in 1950,
then the amendments made by this section shall not be applicable
with respect to any of the distributive shares of income derived by the
family partners from such taxable year of the partnership.
And the Senate agree to the same.
Amendment numbered 92:
That the House recede from its disagreement to the amendment of
the Senate numbered 92, and agree to the same with the following
amendments :
On page 103, line 5, of the Senate engrossed amendments, strike
out "340" and insert 341.
On page 106 of. the Senate engrossed amendments, strike out all
after line 3 over to and including line 23 on page 110 and insert:
" (3) TAX ADJUSTMENT MEASURED BY PRIOR BENEFITS.-If
the provisions of this paragraph are applicable to the taxable year
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r
d
g ap s a e re aced for the purposes of subparagraphs
(B) and (C) by the amount of the obligations or liabilities with
respect to the property considered under subsection (a) as
destroyed or seized in respect of which the recovery was received,
ose under sub-
section (b) (2) to treat such obligations or liabilities as discharged
or satisfied out of such property, and such obligations or
liabilities were not so discharged or satisfied prior to the date
of the recovery.
"(B) Adjustment for Prior Tax Benefits.-That part of the
amount of the recovery, in respect of any property considered
under subsection (a) as destroyed or seized, which is not in
excess of the allowable deductions in prior taxable years on
account of such destruction or seizure of the property (the
amount of such allowable deductions being first reduced by the
aggregate amount of any prior recoveries in respect of the same
property) shall be excluded from gross income for the taxable
year of the recovery for the purpose of computing the tax under
this chapter and chapter ,2; but there shall be added to, and
assessed and collected as a part of, the tax under this chapter
for the taxable year of the recovery the total increase in the tax
under this chapter and chapter 2 for all taxable years which
would result by decreasing, in an amount equal to such part of
the recovery so excluded, such deductions allowable in the prior
taxable years with respect to the destruction or seizure of the
property. Such increase in the tax for each such year so
resulting shall be computed in accordance with regulations
prescribed by the Secretary. Such regulations shall give effect
to previous recoveries of any kind (including recoveries described
in section 22 (b) (12)) with respect to any prior year, and shall
provide for the case where there was no tax for the prior year,
but shall otherwise treat the tax previously determined for any
year in accordance with the principles set forth in section
3801 (d). All credits allowable against the tax for any year
and all carry-overs and carry-backs affected by so decreasing
the allowable deductions shall be taken into account in com-
puting the increase in the tax, except that the computation of
pursuant to an election made by the taxpayer under the provisions
of paragraph (5)-
"(A) Amount of Recovery.--The amount of the recovery in the
taxable year of any money or property in respect of property
considered under subsection (a) as destroyed or seized in any
prior taxable year shall be an amount equal to the aggregate
of such money and the fair market value of such property,
determined as of the date of the recovery. For the purpose of
this paragraph, in the case of the recovery of the same property
or interest considered under subsection (a) as destroyed or
seized, the fair market value of such property or interest shall,
at the option of the taxpayer, be considered an amount equal to
the adjusted basis (for determining loss) of such property or
interest in the hands of the taxpayer on the date such property
or interest was considered under subsection (a) as destroyed or
seized. The amount of the recovery determined under this Aft
sub "-
h h ll b
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REVENUE ACT OF 1951 23
the excess profits credit under chapter 2 E for any taxable year
shall not be affected.
"(C) Gain Upon Recovery.-The amount of any recovery or
part thereof, in respect of property considered under subsection
(a) as destroyed or seized, which is not excluded from gross
income under the provisions of subparagraph (B) shall be con-
sidered for the taxable year of the recovery as gain on the involun-
tary conversion of property as a result of its destruction or
seizure and shall be recognized or not recognized as provided
in section 112 (f).
"(D) Recoveries Treated as Gross Income for Certain Pur-
poses.-For the purposes of sections 51, 52, and 3801 (b) the
recovery in the taxable year of any money or property in respect
of property considered under subsection (a) as destroyed or
seized in any prior taxable year shall be deemed to be an item
includible in gross income for the taxable year in which the
recovery is made. -
"(4) RESTORATION OF VALUE OF INVESTMENTS REFERABLE TO
DESTROYED OR SEIZED PROPERTY.-For the purpose of this sub-
section the restoration in whole or in part of the value of any interest
d in subsection (a) (3) by reason of any recovery of money
ib
d
e
escr
or property in respect of property to which such interest related and
which was considered under subsection (a) (1) or (2) as destroyed
or seized shall be deemed a recovery of property in respect of prop-
erty considered under subsection (a) as destroyed or seized. In
applying paragraph (3) of this subsection such restoration shall be
treated as the recovery of the same interest considered under subsec-
tion (a) as destroyed or seized.
" (5) ELECTION BY TAXPAYER FOR APPLICATION OF PARAGRAPH
(3).-If the taxpayer elects to have the provisions of paragraph (3)
applicable to any taxable year in which he recovered any money or
property in respect of property considered under subsection (a) as
destroyed or seized, the provisions of paragraph (3) shall be appli-
cable to all taxable years of the taxpayer beginning after December
31, 1941, and such election, once made, shall be irrevocable. The
election shall be made in such manner and at such time as the Secre-
tary may by regulations prescribe, except that no election under this
paragraph may be made after December 31, 1952, unless the taxpayer
recovers money or property (in respect of property considered under
subsection (a) as destroyed or seized) dining a taxable year ending
after the date of the enactment of the Revenue Act of 1951. If pur-
suant to such election the provisions of paragraph (3) are applicable
to any taxable year-
"(A) the period of limitations provided in sections 275 and
276 on the making of assessments and the beginning of distraint
or a proceeding in court for collection shall not, with respect
to-
44(i) the amount to be added to the tax for such taxable
year under the provisions of paragraph (3), and
"(ii) any deficiency for such taxable year or for any
other taxable year, to the extent attributable to the basis of
the recovered property being determined under the pro-
visions of subsection (d) (s),.
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expire prior to the expiration of two years following the date
of the making of such election; and such amount and such
deficiency may be assessed at any time prior to the expiration
q f such period notwithstanding any law or rule of law which
would otherwise prevent such assessment and collection, and
"(B) in case refund or credit of any overpayment resulting
from the application of the provisions of paragraph (3) to such
taxable year is prevented on the date of the making of such elec-
tion, or within one year from such date, by the operation of any
law or rule of law (other than section 3761, relating to com-
promises), refund or credit of such overpayment may, never-
theless, be made or allowed if claim therefor is filed within one
year from such date.
In the case of any taxable year ending before the date of the making
by the taxpayer of an election under this paragraph, no interest shall
be paid on any overpayment resulting from the application of the
provisions of paragraph (3) to such taxable year, and no interest shall
be assessed or collected with respect to any amount or any deficiency
specified in clause (A), for any period prior to the expiration of
six months following the date of the making of such election by the
taxpayer."
On page 112 of the Senate engrossed amendments strike out line
6 and all that follows through line 17 and insert:
"(2) PROPERTY RECOVERED IN TAXABLE YEAR TO WHICH
SUBSECTION (C) (3) is APPLICABLE.-In the case of a taxpayer who
has made an election under the provisions of subsection (c) (5), the
basis of property recovered shall be an amount equal to the value at
which such property is included in the amount of the recovery under
subsection (c) (3) (A) (determined without regard to the last sentence
thereof), reduced by such part of the gain under subsection (c) (3)
(C) which is not recognized as provided in section 112 (f)."
On page 113, line 2, of the Senate engrossed amendments, strike
out "1940" and insert 19./1
And the Senate agree to the same.
Amendment numbered 93:
That the House recede from its disagreement to the amendment of
the Senate numbered 93, and agree to the same with an amendment
as follows:
On page 113, line 4, of the Senate engrossed amendments, strike out
"341" and insert 342; and the Senate agree to the same.
Amendment numbered 96:
That the House recede from its disagreement to the amendment of
the Senate numbered 96, and agree to the same with an amendment
as follows:
In lieu of the matter proposed to be inserted by the Senate amend..
ment insert the following:
SEC. 344. NONBUSINESS CASUALTY LOSSES.
(a) REMOVAL OF LIMITATION.-Section 122 (d) (5) (relating to net
operating loss deduction) is hereby amended. by inserting at the end thereof
the following new sentence: "This paragraph shall not apply with respect
to deductions allowable for losses sustained after December 31, 1950,
ANA
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25
in respect of property, if the losses arise from fire, storm, shipwreck, or
other casualty, or from theft."
(b) ErFECTIVE DATE.-The amendment made by this section shall be
applicable in computing the net operating loss deduction for taxable years
ending after December 31, 1948.
And the Senate agree to the same.
Amendment numbered 97:
That the House recede from its disagreement to the amendment of
the Senate numbered 97, and agree to the same with an amendment
as follows:
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following:
SEC. 345. ABATEMENT OF TAX ON CERTAIN TRUSTS FOR
MEMBERS OF ARMED FORCES DYING IN
SERVICE.
In the case of a trust which accumulated income for a beneficiary who
died on or after December 7, 1941, and before January 1, 1948, while in
active service as a member of the military or naval ,forces of the United
States or of any of the other United Nations, there shall be allowed as a
deduction in computing the net income of such trust (in addition to other
deductions allowable under sections 23 and 162 of the Internal Revenue
Code) income of the trust for any taxable year (before diminution for
income tax) which was accumulated for such beneficiary if-
(1) the income accumulated uas for a. taxable year of the trust
which ended with or within a taxable year (ending on orhafter Dece as
ber 7, 1941) of such beneficiary during any part o u
member of such military or naval forces, or, in the case of the taxable
year of the trust during which such beneficiary died, the income
accumulated was for the period in such taxable year prior to the
death of such beneficiary; and
(2) the amount of such accumulated income was, without regard
to this section, taxable to the trust, and
(3) the income for such taxable year accumulated for the bene-
ficiary, if not distributed to him prior to his death, was payable by
the trust at or after his death only to his estate, spouse, or lineal
ancestors or descendants.
And the Senate agree to the same.
Amendment numbered 99:
That the House recede from its disagreement to the amendment of
the Senate numbered 99, and agree to the same with an amendment as
follows:
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following:
SEC. 346. LIFE INSURANCE DEPARTMENTS OF MUTUAL
SAVINGS BANKS.
(a) COMPUTATION of TAx.-Supplement A of chapter 1 is hereby
amended by adding at the end thereof the following new section:
"SEC. 110. MUTUAL SAVINGS BANKS CONDUCTING LIFE
INSURANCE BUSINESS.
"(a) ALTERNATIVE TAx.-In the case of a mutual savings bank not
having capital stock represented by shares, authorized under State law to
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REVENUE ACT OF 1951
engage in the business of issuing life insurance contracts, and which con-
ducts a life insurance business in a separate department the accounts of
which are maintained separately from the other accounts of the mutual
savings bank, there shall be levied, collected, and paid, in lieu of the taxes
imposed by sections 13 and 15, or section 117 (c) (1), a tax consisting of the
sum of the partial taxes determined under paragraphs (1) and (2):
"(1) A partial tax computed upon the net income determined
without regard to any items of gross income or deductions properly
allocable to the business of the life insurance department, at the rates
and in the manner as if this section has not been enacted; and
"(2) a partial tax computed upon the net income (as defined in
section 201 (c) (7)) of the life insurance department determined
without regard to any items of gross income or deductions not prop-
erly allocable to such department, at the rates and in the manner
provided in Supplement G with respect to life insurance companies.
"(b) LIMITATIONS OF SECTION.--The provisions of subsection (a)
shall be applicable only if the life insurance department would
if it were
,
treated as a separate corporation, qualify as a life insurance company
under section 201 (b).11
(b) TECHNICAL AMENDMENT.-Section 13 (relating to normal tax on
corporations) is hereby amended by adding at the end thereof the following
new subsection:
" (f) MUTUAL SAVINGS BANKS CONDUCTING LIFE INSURANCE
BUSINESS.--For special tax, in lieu of the taxes imposed by this section
and section 15, in the case of a mutual savings bank conducting a life
insurance business, see section 110."
(c) EFFECTIVE DATE.-The amendments made by this section shall be
applicable only with respect to taxable years beginning after December 31,
1951.
And the Senate agree to the same.
Amendment numbered 100:
That the House recede from its disagreement to the amendment of
the Senate numbered 100, and agree to the same with the following
amendments:
On page 120, line 17, of the Senate engrossed amendments, strike
out "348" and insert 347.
On page 120, line 23, of the Senate engrossed amendments, strike
out "the taxable year" and insert a taxable year beginnin
before
g
January 1, 1953
And the Senate agree to the same.
Amendment numbered 101:
That the House recede from its disagreement to the amendment of
the Senate numbered 101, and agree to the same with an amendment
as follows:
In lieu of the_ matter proposed to be inserted by the Senate amend-
ment insert the following:
SEC. 348. DEDUCTION WITH RESPECT TO CERTAIN UN-.
]?ELATED BUSINESS NET INCOME.
(a) UNRELATED BUSINESS NET INCOME.-Section 422 (a) (relating
to unrelated business net income) is hereby amended by adding at the
end thereof the following: "In the case of an organization described
in section 3813 (a) (2) which is a member of a partnership all of whose
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REVENUE ACT OF 1951 27
members are organizations described in section 3813 (a) (2), if a trade
or, business regularly carried on by such partnership is an unrelated
trade or business with respect to such organization, such organization
shall, for taxable years beginning before January 1, 1954, be allowed a
deduction in an amount equal to the portion of the gross income "o/' such
partnership from such unrelated trade or business which such organization
is required (by a provision of a written contract executed by such organi-
zation prior to January 1, 1950, which provision expressly deals with
the disposition of the gross income of the partnership) to pay within the
taxable year in discharge of indebtedness incurred by such organization
in acquiring its share of such, trade or business, or to irrevocably set aside
within the taxable year for the discharge of such indebtedness (to the
extent that such amount has been so paid or set aside) if (i) such partnership
was formed prior to January 1, 1950, for the purpose o f carrying on such
trade or business, and (ii) substantially all the assets used in carrying on
such trade or business were acquired by it or by its members prior to such
date. As used in the preceding sentence, the word `indebtedness' does
not include indebtedness incurred after January 1, 1950."
(b) EFFECTIVE DATE.-The amendment made by this section shall be
applicable with respect to taxable years beginning after December 31, 1950,
and prior to January 1, 1954.
And the Senate agree to the same.
Amendment numbered 102:
That the House recede from its disagreement to the amendment of
the Senate numbered 102, and agree to the same with an amendment
as follows :
On page 122, line 8, of the Senate engrossed amendments, strike
out "350" and insert 349; and the Senate agree to the same.
Amendment numbered 104:
That the House recede from its disagreement to the amendment of
the Senate numbered 104, and agree to the same with the following
amendments :
On page 124, line 11, of the Senate engrossed amendments, strike
out "contributions-" and insert the following: contributions;
On page 124 of the Senate engrossed amendments, after line 11,
insert the following:
"(v) an organization organized (prior to October 1,
1951) which is exempt under section 101 (6) and which is
operated for the purpose of conducting an annual chau-
tauqua program of educational, cultural, and religious
activities at a permanent location
And the Senate agree to the same.
Amendment numbered 107:
That the House recede from its disagreement to the amendment of
the Senate numbered 107, and agree to the same with an amendment
as follows:
On page 126 of the Senate engrossed amendments strike out
"January" in lines 18 and 19 and insert April; and the Senate agree
to the same.
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REVENUE ACT OF 1951
Amendment numbered 110:
That the House recede from its disagreement to the amendment of
the Senate numbered 110, and agree to the same with the following
amendments:
On page 127 of the Senate engrossed amendments strike out
"January" in lines 8, 16, 22, and 23 and insert April
On page 127, line 18, or the Senate engrossed amendments strike
out "April" and insert duly
On page 128 of the Senate engrossed amendments strike out
"January" in lines 6 and 9 and insert April
And the Senate agree to the same.
Amendment numbered 111:
That the House recede from its disagreement to the amendment of
the Senate numbered 111, and agree to the same with an amendment
as follows:
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following:
SEC. 423. REDUCTION OF TAX ON TOBACCO AND SNUFF.
(a) REDUCTION IN RATE.-Section 2000 (a) (relating to tax on
tobacco and snuff) is hereby amended by striking out "18 cents per
pound", wherever it appears therein, and inserting in lieu thereof "10
cents per pound".
(b) EFFECTIVE DATE.-The amendment made by subsection (a) shall
take effect on the first day of the first month which begins more than ten
days after the date of the enactment of this Act.
And the Senate agree to the same.
Amendment numbered 118:
That the House recede from its disagreement to the amendment of
the Senate numbered 118, and agree to the same with an amendment
as follows:
Restore the matter proposed to be stricken out by the Senate amend-
ment and on page 111 of the House engrossed bill, after line 16, in-
sert: On and after April 1, 1954, the tax imposed by this section shall be
1% cents a gallon in lieu of 2 cents a gallon.
And the Senate agree to the same.
Amendment numbered 121:
That the House recede from its disagreement to the amendment of
the Senate numbered 121, and agree to the same with an amendment
as follows:
On page 130, line 18, of the Senate engrossed amendments, strike
out "January" and insert April; and the Senate agree to the same.
Amendment numbered 122:
That the House recede from its disagreement to the amendment of
the Senate numbered 122, and agree to the same with an amendment
as follows:
On page 131, line 1, of the Senate engrossed amendments, strike
out "January" and insert April; and the Senate agree to the same.
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Amendment numbered 127:
That the House recede from its disagreement to the amendment
of the Senate numbered 127, and agree to the same with an amend-
ment as follows:
On page 131, line 8, of the Senate engossed amendments, strike
out "January" and insert April; and the Senate agree to the same.
Amendment numbered 128:
That the House recede from its disagreement to the amendment of
the Senate numbered 128, and agree to the same with an amendment
as follows :
On page 131, line 11, of the Senate engrossed amendments, strike
out "January" and insert April; and the Senate agree to the same.
Amendment numbered 129:
That the House recede from its disagreement to the amendment of
the Senate numbered 129, and agree to the same with an amendment
as follows:
On page 131, line 14, of the Senate engrossed amendments, strike
out "January" and insert April; and the Senate agree to the same.
Amendment numbered 131:
That the House recede from its disagreement to the amendment of
the Senate numbered 131, and agree to the same with an amendment
as follows:
On page 132 of the Senate engrossed amendments strike out "Janu-
ary" in lines 1 and 8 and insert April; and the Senate agree to the same.
Amendment numbered 137:
That the House recede from its disagreement to the amendment. of
the Senate numbered 137, and agree to the same with an amendment
as follows:
On page 132, line 17, of the Senate engrossed amendments, strike
= out "January" and insert April; and the Senate agree to the same.
Amendment numbered 1.41
That the House recede from its disagreement to the amendment of
the Senate numbered 141, and agree to the same with the following
amendments:
On page 133, line 3, of the Senate engrossed amendments, strike
out "444" and insert 454
On page 133 of the Senate engrossed amendments strike out "Jan-
uary" in lines 11 and 18 and insert April
On page 133, line 20, of the Senate` engrossed amendments, strike.
out "February" and insert May
On page 134, line 2, of the Senate engrossed amendments, strike
out "January" and insert April
And the Senate agree to the same.
Amendment numbered 142:
That the House recede from its disagreement to the amendment of
the Senate numbered 142, and agree to the same with an amendment
as follows:
In lieu of the matter proposed to be inserted: by the Senate amend-
ment insert the following: 455; and th.e Senate agree to the same.
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Amendment numbered 143:
That the House recede from its disagreement to the amendment of
the Senate numbered 143, and agree to the same with an amendment
as follows:
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following: 456; and the Senate agree to the same.
Amendment numbered 151:
That the House recede from its disagreement to the amendment of
the Senate numbered 151, and agree to the same with the following
amendments:
On page 135, of the Senate engrossed amendments, strike out "452"
in lines 8 and 13 and insert 462
On page 135, line 16, of the Senate engrossed amendments, strike
out "December 31, 1953" and insert March 31, 1954
And the Senate agree to the same.
Amendment numbered 154:
That the House recede from its disagreement to the amendment of
the Senate numbered 154, and agree to the same with an amendment
as follows:
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following: 464; and the Senate agree to the same.
Amendment numbered 156:
That the House recede from its disagreement to the amendment
of the Senate numbered 156, and agree to the same with an amend-
ment as follows:
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following: 461 and 463; and the Senate agree to the
same.
Amendment numbered 163:
That the House recede from its disagreement to the amendment of
the Senate numbered 163, and agree to the same with the following
amendments :
On page 136, line 18, of the Senate engrossed amendments, strike
out "461" and insert 471
On page 137, line 5, of the Senate engrossed amendments, strike
out "461" and insert 471
And the Senate agree to the same.
Amendment numbered 166:
That the House recede from its disagreement to the amendment of
the Senate numbered 166, and agree to the same with an amendment
as follows:
On page 137, line 13, of the Senate engrossed amendments, strike
out "January" and insert April ; and the Senate agree to the same.
Amendment numbered 167:
That the House recede from its disagreement to the amendment of
the Senate numbered 167, and agree to the same with, an amendment.
as follows:
On page 137, line 23, of the Senate engrossed amendments, strike
out "January" and insert April; and the Senate agree to the same
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Amendment numbered 168:
That the House recede from its disagreement to the amendment of
the Senate numbered 168, and agree to the same with an amendment
as follows :
On page 138, line 5, of the Senate engrossed amendments, strike out
"January" and insert April; and the Senate agree to the same.
Amendment numbered 172:
That the House recede from its disagreement to the amendment of
the Senate numbered 172, and agree to the same with an amendment
as follows :
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following: 490; and the Senate agree to the same.
Amendment numbered 173:
The the House recede from its disagreement to the amendment of
the Senate numbered 173, and agree to the same with the following
amendments:
On page 138, line 19, of the Senate engrossed amendments, strike
out "473" and insert 483
On page 139, line 7, of the Senate engrossed amendments, strike out
"producer or" and insert producer of
And the Senate agree to the same.
Amendment numbered 174:
That the House recede from its disagreement to the amendment of
the Senate numbered 174, and agree to the same with the following
amendments:
On page 139, line 19, of the Senate engrossed amendments, strike
out "474" and insert 484
On page 140 of the Senate engrossed amendments strike out lines
19, 20, and 21 and, in lieu thereof, insert the following: 15 per centum,
except that on and after April 1, 1954, the rate shall be 10 per centum;
fishing rods, creels, reels, and artificial lures, baits, and ~Ties; 10 per
centum."
And the Senate agree to the same.
Amendment numbered 175:
That the House recede from its disagreement to the amendment of
the Senate numbered 175, and agree to the same with an amendment
as follows:
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following: 485; and the Senate agree to the same.
Amendment numbered 178:
That the House recede from its disagreement to the amendment of.
the Senate numbered 178, and agree to the same with). an amendment
as follows:
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following: by striking out "Electric direct motor-driven
fans and air Circulators;" and inserting in lieu thereof "Electric direct
motor-driven fans and air circulators (not of the industrial type; and the
following appliances of the household type:", (2); and the Senate agree
to the same.
Approved For Release 2007/02/24: CIA-RDP57-00384R001200010010-8
Approved For Release 2007/02/24: CIA-RDP57-00384R001200010010-8
REVENUE ACT OF 1951
Amendment numbered 179:
That the House recede from its disagreement to the amendment of
the Senate numbered 179, and agree to the same with an amendment
as follows:
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following: (3), and on page 139 of the House engrossed
bill, in lines 3 and 4, strike out "and the following appliances of the
household type:"; and the Senate agree to the same.
Amendment numbered 181:
That the House recede from its disagreement to the amendment of
the Senate numbered 181, and agree to the same with an amendment
as follows:
Strike out the matter proposed to be stricken out by the Senate
amendment and omit the matter proposed to be inserted by the
Senate amendment; and the Senate agree to the same.
Amendment numbered 184:
That the House recede from its disagreement to the amendment of
the Senate numbered 184, and agree to the same with an amendment
as follows:
Restore the matter proposed to be stricken out by the Senate amend-
ment, omit the matter proposed to be inserted by the Senate amend-
ment, and on page 139, line 11, of the House engrossed bill, strike out
"485" and insert 486; and the Senate agree to the same.
Amendment numbered 185:
That the House recede from its disagreement to the amendment of
the Senate numbered 185, and agree to the same with an amendment
as follows:
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following: 487; and the Senate agree to the same.
Amendment numbered 188:
That the House recede from its disagreement to the amendment of
the Senate numbered 188, and agree to the same with an amendment
as follows:
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following: 15; and the Senate agree to the same.
Amendment numbered 191:
That the House recede from its disagreement to the amendment of
the Senate numbered 191, and agree to the same with an amendment
as' follows:
In lieu of the matter proposed to be inserted by the Senate amend-
ment insert the following: 488; and the Senate agree to the same.
Amendment numbered 193:
That the House recede from its disagreement to the amendment of
the Senate numbered 193, and agree to the same with an amendment
as follows:
In lieu of the matter proposed to be inserted by. the Senate amend-
ment insert the following: 489; and the Senate agree to the same.
Approved For Release 2007/02/24: CIA-RDP57-00384R001200010010-8