Willamette Industries, Inc. - Page 9




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               prior commitment of capital within the period provided                 
               by the statute.  The statute is to be liberally                        
               construed to accomplish this purpose.  On the other                    
               hand, it was not intended to confer a gratuitous                       
               benefit upon the taxpayer by permitting him to utilize                 
               the involuntary interruption in the continuity of his                  
               investment to alter the nature of that investment tax                  
               free. * * *                                                            
          Filippini v. United States, 318 F.2d 841, 844 (9th Cir. 1963).              
               The earliest predecessor of section 1033 was section                   
          214(a)(12) of the Revenue Act of 1921, ch. 136, 42 Stat. 227                
          (1921 Act).  Except for certain modifications not pertinent to              
          the question we consider, the purpose and substance of section              
          214(a)(12) of the 1921 Act was the same as the version of section           
          1033 under consideration in this case.                                      
               Only a limited amount of legislative history has accompanied           
          the enactment of the various involuntary conversion relief                  
          provisions since 1921.  The House and Senate reports issued in              
          connection with section 214(a)(12) of the 1921 Act explained that           
          the relief “permits the taxpayer to omit or deduct the gains                
          involuntarily realized, when he proceeds forthwith in good faith            
          to invest the proceeds of such conversion in the acquisition of             
          similar property or in establishment of a replacement fund                  
          therefor.”  H. Rept. 350, 67th Cong., 1st Sess. 12 (1921), 1939-1           
          C.B. (Part 2) 168, 177; accord S. Rept. 275, 67th Cong., 1st                
          Sess. 15 (1921), 1939-1 C.B. (Part 2) 181, 191.                             
               From that limited legislative history, it can be gleaned               







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