- 6 -
history provides that "with respect to a partnership, the cost of
the property on which additional first-year depreciation is
calculated for the partnership as a whole is not to exceed
$10,000." S. Rept. 94-938, at 92 (1976), 1976-3 C.B. (Vol. 3)
49, 130. Section 179 was amended again by the Economic Recovery
Tax Act of 1981, Pub. L. 97-34, sec. 202(a), 95 Stat. 172, to
provide for an election to expense the cost of property rather
than taking additional depreciation), and that provision did not
amend section 179(d)(8). The committee report states:
Similarly, the same type of dollar limitations will
apply in the case of partnerships as currently apply under
section 179(d)(8). Under the committee bill, as under
section 179, both the partnership and each partner are
subject to the annual dollar limitation. [S. Rept. 97-144,
at 61 (1981), 1981-2 C.B. 412, 431.]
The taxable income limitation contained in current section
179(b)(3)(A) was added by the Tax Reform Act of 1986, Pub. L. 99-
514, sec. 202(a), 100 Stat. 2085, 2143. While the Senate version
of the taxable income limitation of section 202(a) was limited to
taxable income of the business in which property was used, see S.
Rept. 99-313, at 106 (1986), 1986-3 C.B. (Vol. 3) v, 106),
section 179(b)(3), as enacted, applied to taxable income from any
trade or business of the taxpayer. See H. Conf. Rept. 99-841, at
II-49 (1986), 1986-3 C.B. (Vol. 4) 1, 49; see also Staff of Joint
Comm. on Taxation, General Explanation of the Tax Reform Act of
1986 (Jt. Comm. Print 1987), at 109. Concurrently, section
179(d)(8), pertaining to partnerships, was amended to read as it
does now by the Tax Reform Act of 1986, Pub. L. 99-514, sec.
201(d)(3), 100 Stat. 2085, 2139.
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