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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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