Page:United States Statutes at Large Volume 98 Part 1.djvu/650

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PUBLIC LAW 98-000—MMMM. DD, 1984

98 STAT. 602

PUBLIC LAW 98-369—JULY 18, 1984 "(B) INCREASE FOR INTEREST.—

"(i) IN GENERAL.—A reserve shall be increased each taxable year by an amount equal to the amount of interest which would be earned during such taxable year on the opening balance of such reserve for such taxable year if such interest were computed— "(I) at the Federal short-term rate or rates (determined under section 1274) in effect, and "(II) by compounding semiannually, "(ii) PHASE-IN OF INTEREST RATE.—In the case of taxable years ending before 1987, the rate determined under clause (i)(I) shall be equal to the following percentage of such rate (determined without regard to this clause):

Ante, p. 538.

"In the case of taxable years ending in: 1984 or 1985 1986

The percentage is: 70 85.

"(C) RESERVE TO BE CHARGED FOR AMOUNTS PAID.— Any

amount paid by the taxpayer during any taxable year for qualified reclamation or closing costs allocable to portions of the reserve property for which the election under paragraph (1) was in effect shall be charged to the appropriate reserve as of the close of the taxable year. "(3) ALLOWANCE OF DEDUCTION FOR EXCESS AMOUNTS PAID.—

There shall be allowed as a deduction for any taxable year the excess of— "(A) the amounts described in paragraph (2)(C) paid during such taxable year, over "(B) the closing balance of the reserve for such taxable year (determined without regard to paragraph (2)(C)). "(4) LIMITATION ON BALANCE AS OF THE CLOSE OF ANY TAXABLE YEAR.— "(A) RECLAMATION RESERVES.—In the case of any reserve

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for qualified reclamation costs, there shall be included in gross income for any tsixable year an amount equal to the excess of^ "(i) the closing balance of the reserve for such taxable year, over "(ii) the current reclamation costs of the taxpayer for all portions of the reserve property disturbed during any taxable year to which the election under paragraph (1) applies. "(B) CLOSING COSTS RESERVES.—In the case of any reserve for qualified closing costs, there shall be included in gross income for any taxable year an amount equal to the excess of"(i) the closing balance of the reserve for such taxable year, over "(ii) the current closing cost of the taxpayer with respect to the reserve property, determined as if all production with respect to the reserve property for any taxable year to which the election under paragraph (1) applies had occurred in such taxable year.