Page:United States Statutes at Large Volume 98 Part 1.djvu/599

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PUBLIC LAW 98-000—MMMM. DD, 1984

PUBLIC LAW 98-369—JULY 18, 1984 "(2)

98 STAT. 551

DOUBLE INCLUSION IN INCOME NOT REQUIRED.—Section

1281 shall not require the inclusion of any amount previously includible in gross income.

Ante, p. 548.

"(3) COORDINATION WITH OTHER PROVISIONS.—Section 454(b)

and section 1271(a)(3) shall not apply to any short-term obligation to which section 1281 applies.

Ante, p. 532.

"Subpart D—Miscellaneous Provisions "Sec. 1286. Tax treatment of stripped bonds. "Sec. 1287. Denial of capital geiin treatment for gains on certain obligations not in registered form. "Sec. 1288. Treatment of original issue discount on tax-exempt obligations. "SEC. 1286. TAX TREATMENT OF STRIPPED BONDS.

26 USC 1286.

"(a) INCLUSION IN INCOME AS IF BOND AND COUPONS WERE ORIGINAL ISSUE DISCOUNT BONDS.—If any person purchases after July 1,

1982, a stripped bond or a stripped coupon, then such bond or coupon while held by such purchaser (or by any other person whose basis is determined by reference to the basis in the hands of such purchaser) shall be treated for purposes of this part as a bond originally issued on the purchase date and having an original issue discount equal to the excess (if any) of— "(1) the stated redemption price at maturity (or, in the case of coupon, the amount payable on the due date of such coupon), over "(2) such bond's or coupon's ratable share of the purchase price. For purposes of paragraph (2), ratable shares shall be determined on the basis of their respective fair market values on the date of purchase. "(b) TAX TREATMENT OF PERSON STRIPPING BOND.—For purposes of this subtitle, if any person strips 1 or more coupons from a bond and after July 1, 1982, disposes of the bond or such coupon— "(1) such person shall include in gross income an amount equal to the interest accrued on such bond while held by such person and before the time that such coupon or bond was disposed of (to the extent such interest has not theretofore been included in such person's gross income), "(2) the basis of the bond and coupons shall be increased by the amount of the accrued interest described in paragraph (1), "(3) the basis of the bond and coupons immediately before the disposition (as adjusted pursuant to paragraph (2)) shall be allocated among the items retained by such person and the items disposed of by such person on the basis of their respective fair market values, and "(4) for purposes of subsection (a), such person shall be treated as having purchased on the date of such disposition each such item which he retains for an amount equal to the basis allocated to such item under paragraph (3). A rule similar to the rule of paragraph (4) shall apply in the case of any person whose basis in any bond or coupon is determined by reference to the basis of the person described in the preceding sentence. "(c) RETENTION OF EXISTING LAW FOR STRIPPED BONDS PURCHASED BEFORE JULY 2, 1982.—If a bond issued at any time with interest

coupons—

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