- 88 - contained transitional rules that excepted “transition property” from the repeal of the ITC.97 Sec. 49(b). Section 49(e) defined “transition property” as: SEC. 49(e). Transition Property.--For purposes of this section-- (1) Transition property.--The term “transition property” means any property placed in service after December 31, 1985, and to which the amendments made by section 201[98] of the Tax Reform Act of 1986 do not apply, except that in making such determination-- (A) section 203(a)(1)(A) of such Act shall be applied by substituting “1985” for “1986”, (B) sections 203(b)(1) and 204(a)(3) of such Act shall be applied by substituting “December 31, 1985” for “March 1, 1986”, (C) in the case of transition property with a class life of less than 7 years-- 97 The transitional rules were intended to provide relief to taxpayers who may have committed to post-1985 investments in qualifying property in reliance on the availability of the credit. See Newhouse Broad. Corp. v. Commissioner, T.C. Memo. 2000-270. The House Ways and Means Committee made the following observation with respect to the repeal of the ITC: 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. H. Conf. Rept. 99-426, at 146 (1985), 1986-3 C.B. (Vol. 2) 1, 146. 98 TRA sec. 201, 100 Stat. 2121, amended sec. 168, which relates to the accelerated cost recovery system.Page: Previous 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 Next
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