Newhouse Broadcasting Corp. and Subsidiaries, et al. - Page 14




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            year (qualifying property).  The amount of the credit depended                             
            upon the useful life of the qualifying property.  The maximum                              
            credit was 10 percent of the cost of qualifying property with a                            
            useful life of 7 years or more.  The credit was repealed by                                
            section 211 of TRA of 1986, 100 Stat. 2166, which added section                            
            494 to the Internal Revenue Code.  Section 49(a), made the                                 
            investment credit inapplicable to property placed in service                               
            after December 31, 1985.  Because TRA of 1986 did not become law                           
            until October 22, 1986, the repeal of the investment credit was                            
            necessarily retroactive.  Therefore, the Act contains a number of                          
            transitional rules to provide relief for taxpayers who may have                            
            committed to post-1985 investments in qualifying property in                               
            reliance on the availability of the credit.5  Pursuant to section                          
            49(b)(1), the section 49(a) repeal of the credit does not apply                            



            4  Sec. 11813 of the Omnibus Budget Reconciliation Act of 1990,                            
            Pub. L. 101-508, 104 Stat. 1388-536, repealed sec. 49 and                                  
            replaced it with existing sec. 49 (at-risk rules).                                         
            5  See H. Rept. 99-426 at 146 (1985), 1986-3 C.B. (Vol. 2) 1,                              
            146, in which the House Ways and Means Committee makes the                                 
            following observation with respect to the repeal of the then                               
            existing cost recovery rules, including the investment tax                                 
            credit:                                                                                    
                        The committee is aware that commitments have                                   
                  already been made on the basis of present law capital                                
                  cost recovery rules.  The committee bill provides for                                
                  equitable transition rules in such cases, which are                                  
                  estimated to cover more than 50 percent of the new                                   
                  personal property to be placed in service in the first                               
                  year the bill is effective.                                                          





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