514
Ante, p. 496. 53 Stat. 27, 471. 26 U.S.C. §§51, 52, 3801 (b). Ante, pp. 482, 488.
PUBLIC LAW 183—OCT. 20, 1951
be considered for the taxable year of the recovery as gain on the involuntary 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 Purposes.—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)
56 Stat. 852. 26 U.S.C. §127 (a).
Post, p. 516.
53 Stat. 462. 26 U.S.C. § 3761.
RESTORATION
OP VALUE OF INVESTMENTS REFERABIIE TO
DESTROYED O SEIZED PROPERTY.—For the purposc of this subsection R the restoration in whole or in part of the value of any interest described in subsection (a)(3) by reason of any recovery of money 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 property considered under subsection (a) as destroyed or seized. I n applying paragraph (3) of this subsection such restoration shall be treated as the recovery of the same interest considered under subsection (a) as destroyed or seized. "(5)
53 Stat. 86. 26 U.S.C. §§ 275, 276. Ante, p. 497.
[65 STAT.
ELECTION BY TAXPAYER FOR.\PPLICATION OF PARAGIJAPH
(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 oi property considered under subsection (a) as destroyed or seized, the provisions of paragraph (3) shall be applicable 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 Secretary 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) during a taxable year ending after the date of the enactment of the Revenue Act of 1951. If pursuant 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— " (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 provisions of subsection (d)(2), 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 of 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 taxal)le year is prevented on the date of the making of such election, or within one year from such date, by the operation of any law or rule of law (other than section 3761, relating to compromises), refund or credit of such overpay-
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