806 INC OME TAX Recognition of g ain or loss on disposition of installmentobligatious. Basis computed . Allocatio n of income and deductions . Provisions if same interests control two or more businesses. Change of accounting period . Net income co m- puted on basis of new period . Returns for less than a year. Basis for determin- ing, when accounting periods change . Income to be bas ed on period of separate return . Computation of ta x- able income . SEVENTIETH CONGRESS . SESS . I . CH. 852. 1928 . (d) Gain or loss upon disposition of installment obligations .-If an installment obligation is satisfied at other than its face value or distributed, transmitted, sold, or otherwise disposed of, gain or loss shall result to the extent of the difference between the basis of the obligation and (1) in the case of satisfaction at other than face value or a sa le or exchange-the amount realized, or (2) in case of a distribution, transmission, or disposition other- wise than by sale or exchange-the fair market value of the obliga- tion at the time of such distribution, transmission, or disposition . The basi s of the obligat ion shall be the excess of the fa ce value of the obligation over an amount equal to the income which would he returnable were the obligation satisfied in full . SEC. 45. ALL OC AT ION OF INCOME AND DEDUCTIONS . In any case of two or more trades or businesses (whether or not in corpor ated, whet her or not organ ized i n the Unit ed Sta tes, and whether or not affiliated) owned or controlled directly or indirectly by t he same interest s, the C ommission er is au thorized to dist ribute, apportion, or allocate gross income or deductions between or among such trades or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such trades or businesses. SEC . 46. CHANGE OF ACCOUNTING PERIOD . If a taxpayer changes his accounting period from fiscal year to cale ndar yea r, from calendar year to fiscal y ear, or from one fiscal year to another, the net income shall, with the approval of the Co mmiss ione r, be co mput ed on the b asis of such new acc ount ing period, subject to the provisions of section 47 . SEC . 47. RETU RNS FOR A PERIO D OF LESS THAN TWELV E MONTHS. (a) Returns for short period resulting from change of accounting period .-If a taxpayer, with the approval of the Commissioner, ch anges the bas is of co mpu ting net inc ome from fis cal year to calendar year a separate return shall be made for the period between the close of the last fiscal year for which return was made and the fol lowi ng D ecem ber 31. If the change is from calendar year to fiscal year, a separate return shall be made for the period be tw een the cl ose of the la st calendar yea r for which return was made and the date designated as the close of the fiscal year . If the change is from one fiscal year to another fiscal year a separate return shall be made for the period between the close of the former fiscal yea r and the date designated as the close of the new fiscal year . (b) Income computed on basis of short period .-Where a separate return is ma de und er subs ect ion (a) on a ccou nt of a change in the accounting period, and in all other cases where a separate return is required or permitted, by regulations prescribed by the Commissioner with the approval of the Secretary, to be made for a fractional part of a year, then the income shall be computed on the basis of the period for which separate return is made . (c) Income placed on annual basis .-If a separate return is made un der s ubse ctio n (a) on ac coun t of a change in the acc ount ing period, the net income, computed on the basis of the period for which separate return is made, shall be placed on an annual basis by multiplying the amount thereof by twelve and dividing by the number of months i ncluded in the period for w hich the separate return is made. The tax shall be such par t of the tax computed
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