210 INCOME TAX M Income from sources within and part- without United States . Apportionment . From United States sources. Computation of net income. Processes, etc., for determination . Gains from transpor- tation or other services. Sale of personal prop- erty within and with- out. Purchase and sale of personal property . Exceptions. Definitions . Cha rita ble cont ribu - tions,etc . Unlimited deduction allowed, if exceed 90 per cent of income. Ante, p . 181. 72d CONGRESS . SESS. I. CH. 209. JUNE 6,1932 . any, shall be treated in full as net income from sources without the United States. (e) INCO ME FR OM S OURC ES PARTLY WITHIN AND PARTLY WITHOUT UNrrED STATES .-Items of gross income, expenses, losses and deduc- tions, other than those specified in subsections (a) and (c) of this section, shall be allocated or apportioned to sources within or without the United States, under rules and regulations prescribed by the Commissioner with -the approval of the Secretary . Where items of gross income are separately allocated to sources within the United States, there shall be deducted (for the purpose of computing the net income therefrom) the expenses, losses, and other deductions properly apportioned or allocated thereto and a ratable part of other expenses, losses or other deductions which can not definitely be allocated to some item or class of gross income . 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 apportioned or allocated thereto and a ratable part of any expenses, losses, or other deductions which can not definitely be allocated to some items or class of gross income ; and the portion of such net income attributable to sources within the United States may be determined by processes or formulas of general apportionment 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 without and sold within the United States, shall be treated as derived partly from sources within and partly from sources without the United 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 ent irely from sources within the country in which sold except that gains, profits, and income derived from the purchase oy personal property within the United States and its sale within a - possession 7the United States or from the purchase of personal property within a possession of the United States and its sale within the United States shall be treated as derived partly from sources within and partly from sources without the United States . (f) DEFINrrioNs .--As used in this section the words "sale" or "sold" i nclu de " exchange " or " exchanged " ; and the word "
cc produced ƒ includes " created," fabricated," " manufactured," "extracted," "processed," "cured," or " aged." SEC. 120. UNLIMITED DEDUCTION FOR CHARITABLE AND OTHER CONTRIBUTIONS. p 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- profi ts, or e xces s-pr ofit s ta xes paid dur ing such yea r in res pect of receding taxable years, exceeds 90 per centum of the taxpayer's net income for each such year, as computed without the benefit of section 23(n), then the 15 per centum limit imposed by such section shall not be applicable .
