72 S T A T. ]
P U B U C LAW 85-866-8EPT. 2, 1968
SEC. 91. SEALS FOR OFFICES OF TREASURY DEPARTMENT. (a) AUTHORITY TO PRESCRIBE SEALS.—Chapter 77 (relating to miscellaneous provisions) is amended by adding after section 7513 (added by section 90 of this Act) the following new section: "SEC. 7514. AUTHORITY TO PRESCRIBE OR MODIFY SEALS. "The Secretary or his delegate is authorized to prescribe or modify seals of office for the district directors of internal revenue and other officers or employees of the Treasury Department to whom any of the functions of the Secretary shall have been or may be delegated. Each seal so prescribed shall contain such device as the Secretary or his delegate may select. Each seal shall remain in the custody of any officer or employee whom the Secretary or his delegate may designate, and, in accordance with the regulations approved by the Secretary or his delegate, may be affixed in lieu of the seal of the Treasury Department to any certificate or attestation (except for material to be published in the Federal Kegister) that may be required of such officer or employee. Judicial notice shall be taken of any seal prescribed in accordance with this authority, a facsimile of which has been published in the Federal Eegister together with the regulations prescribing such seal and the affixation thereof." (b) TECHNICAL AMENDMENT.—The table of sections for such chapter is amended by adding at the end thereof the following: "Sec. 7514. Authority to prescribe or modify seals." SEC. 92. INCOME TAXES PAID UNDER CONTRACT. (a) AMENDMENT OF 1939 CODE.—Section 22 of the Internal Revenue Code of 1939 is amended by adding after subsection (o) the following new subsection:
- '(p) INCOME TAXES PAID UNDER (^ONTRACT BY O N E CORPORATION
F R ANOTHER CORPORATION.—If— O
"(1) a contract was entered into before January 1, 1952, (2) under the contract, one party (hereinafter referred to as the 'payor') is obligated to pay, or to reimburse another party (hereinafter referred to as the 'payee') for any part of the tax imposed by this chapter on the payee with respect to the income derived under the contract by the payee from the payor, and " (3) both the payor and the payee are corporations, then gross income of the payee shall not include any such payment or reimbursement other than the payment or reimbursement of the tax imposed by this chapter on the payee with respect to the income derived under the contract by the payee from the payor, determined without the inclusion of any such payment or reimbursement in gross income, and a deduction for all such payments or reimbursements shall be allowed to the payor but only to the extent that any such payment or reimbursement is attributable to an amount paid by the payor to the payee under the contract (other than any payment or reimbursement of the tax imposed by this chapter) which is allowable as a deduction to the payor. For purposes of this subsection, a contract shall be considered to have been entered into before January 1, 1952, if it is a renewal or continuance of a contract entered into before such date and if such renewal or continuance was made in accordance with an option contained in the contract on December 31, 1951. For purposes of this subsection, a contract includes a lease." (b) EFFECTIVE DATE, ETC.—The amendment made by subsection (a) shall apply with respect to taxable years beginning after December 31, 1951, to which the Internal Revenue Code of 1939 applies. If refund or credit of any overpayment resulting from the application of the amendment made by subsection (a) of this section is prevented on the date of the enactment of this Act, or within 6 months from
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^6 USC?:;.
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