Comment
Author: Admin | 2025-04-27
Transaction which constitutes a disposal of coal or iron ore under section 631(c) shall be treated as a disposition. In such a case, the excess referred to in subsection (d)(1)(B) shall be treated as equal to the gain (if any) referred to in section 631(c).(g) Special rules relating to partnership property(2) Property retained by partnershipIn the case of any property or mine held by a partnership after a distribution to a partner to which section 751(b) applied, the adjusted exploration expenditures with respect to such property or mine shall, under regulations prescribed by the Secretary, be reduced by the amount of gain to which section 751(b) applied realized by such partner with respect to such distribution on account of such property or mine.(h) Special rules for foreign explorationIn the case of any expenditures paid or incurred before the development stage for the purpose of ascertaining the existence, location, extent, or quality of any deposit of ore or other mineral (other than an oil, gas, or geothermal well) located outside the United States—(1) subsection (a) shall not apply, and(2) such expenditures shall—(A) at the election of the taxpayer, be included in adjusted basis for purposes of computing the amount of any deduction allowable under section 611 (without regard to section 613), or(B) if subparagraph (A) does not apply, be allowed as a deduction ratably over the 10-taxable year period beginning with the taxable year in which such expenditures were paid or incurred.(i) Cross referenceFor election of 10-year amortization of expenditures allowable as a deduction under this section, see section 59(e).(Added Pub. L. 89–570, § 1(a), Sept. 12, 1966, 80 Stat. 759; amended Pub. L. 91–172, title V, § 504(b), Dec. 30, 1969, 83 Stat. 632; Pub. L. 94–455, title XIX, §§ 1901(a)(89), (b)(3)(K), (21)(C)–(E), 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1779, 1793, 1797, 1834; Pub. L. 97–248, title II, § 201(d)(9)(D), formerly § 201(c)(9)(D), § 224(c)(8), Sept. 3, 1982, 96 Stat. 420, 489, renumbered § 201(d)(9)(D), Pub. L. 97–448, title III, § 306(a)(1)(A)(i), Jan. 12, 1983, 96 Stat. 2400; Pub. L. 99–514, title IV, §§ 411(b)(2)(B), 413(b), Oct. 22, 1986, 100 Stat. 2226, 2228; Pub. L. 100–647, title I, § 1007(g)(7), Nov. 10, 1988, 102 Stat. 3435; Pub. L. 101–508, title XI, § 11801(a)(27), (c)(13), Nov. 5, 1990, 104 Stat. 1388–521, 1388–527.)Editorial NotesAmendments1990—Subsecs. (i), (j). Pub. L. 101–508 redesignated subsec. (j) as (i) and struck out former subsec. (i) which related
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