828 INC OME TAX Deduct ions there- from of designated ex- penses, etc ., consti- tute n et income fr om sources without United States . Apportionment of items within and with- out United States . Fr om United States sources . Derived partly with- in and pa rtly without . Determi nation of United States in- come . From transportation and other ser vices . Sales of personal property within and without . Purchase an d sale of personal property . Exceptions . Synonymous mean . ing of words . Charitable, etc., con- tributions. Unlimited deduction allowed if, exceed 90 per cent of net income . Ante, p . 801. SEVENTIETH CONGRESS . SESS. I . Ca. 852. 1928 . (d) Net income from sources without United States .-From the items of gross income specified in subsection (c) of this section there shall be deducted the expenses, losses, and other deductions properly apportioned or allocated thereto, and a ratable part of any expenses, losses, or other deductions which can not definitely be allocate d to som e item o r class of gross income . The remainder, if any, shall be treated in full as net income from sources without the United States . (e) Income from sources partly within and partly without United States .-Items of gross income, expenses, losses and deductions, other than those specified in subsections (a) and (c) of this section, shall be allocated or apportioned to sources within or without the United S tates, under rules and regulations prescr ibed by the Commissioner with the approval of the Secretary . Where item s of gro ss incom e are se parately allocate d to sou rces wit hin the United States, there shall be deducted (for the purpose of comput- ing the net income therefrom) the expenses, losses and other deduc- tions properly apportioned or allocated thereto and a ratable part of other expenses, losses or other deductions which can not definitely be a llocated to some item or class of gross i ncome . The remainder, if any, shall be included in full as net income from sources within the United States . In the case of gross income derived from sources partly within and partly without the United States, the net income may first be computed by deducting the expenses, losses or other deductions apportion ed or allocated thereto and a ratable par t of any expenses, losses or other deductions which can not defini tely be allocated to some items or class of gross income ; and the portion of such net income attributable to sources within the United States ma y be det ermi ned by p roce sses or form ulas of gene ral appo rtio n- ment prescribed by the Commissioner with the approval of the Secretary . Gains, profits and income from- (1) transportation or other services rendered partly within and partly without the United States, or (2) from the sale of personal property produced (in whole or in part) by the taxpayer within and sold without the United States, or produced (in whole or in part) by the taxpayer with- out and sold w ithin the United States, shall be treated as derived partly from sources within and pa rtly from sources without the Un ited States . Gains, profits and income derived from the purchase of personal property within and its sale without the United States or from the purchase of personal property without and its sale within the United States, shall be treated as derived entirely from sources within the country in which sold, except that gains, profits and income derived from the purchase of personal property within the United States and its sale within a pos- session of the United States or from the purchase of personal prop- erty within a possession of the United States and its sale within the United States shall be treated as deri ved part ly from sources within and partly from sources without the United States. (f) Definitions .-As used in this section the words "sale" or ` sold " include "exchange " or " exchanged " ; and the word " pro- duced " includes " created," "fabricated," " manu fact ured ," " ex- tracted," " processed," " cured," or " aged ." SEC. 120. UNLIMITED DEDUCTION FOR CHARITABLE AND OTHER CONTRIBUTIONS . In the case of an individual if in the taxable year and in each of the ten preceding taxable years the amount of the contributions or gifts described in section 23(n) plus the amount of income, war- profit s, or ex cess-pro fits tax es paid during s uch year in resp ect of
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