“(iii) in May well 1983, the court of best jurisdiction from the State in which the faculty is found fixed the zoning dispute in favor of the school.

(D) Additional depreciation may be claimed just once If this paragraph applies to any specified plant, this kind of specified plant shall not be treated as qualified residence from the taxable yr by which put in provider.

For purposes of the paragraph, all members of the identical affiliated group of firms (in the indicating of part 1504 of The inner Profits Code of 1986) filing a consolidated return shall be taken care of as one particular taxpayer.

(iii) Treatment method of successor corporations Any Corporation which is engaged in activities substantially just like Individuals engaged in by a predecessor Corporation shall be successful towards the treatment method less than this subparagraph of these types of predecessor Corporation.

For applications of the paragraph the term ‘certified particular person’ usually means anyone who transfers his legal rights in this kind of deal or such home for the taxpayer, but only if these kinds of residence is not really put in company by such person prior to this kind of rights are transferred to the taxpayer.

For reasons in the preceding sentence, any exclusion or exemption shall not apply for applications of pinpointing the level of the gross cash flow so derived, but shall apply for functions of determining the percentage of these gross cash flow topic to tax under this chapter.

“(II) bought and leased back by these types of particular person inside three months following the day these home was at first positioned in services,

“(E) Turbines and boilers.—Property is described In this particular subparagraph if these types of property— “(i) is actually a turbine or boiler of the cooperative Group engaged during the furnishing of electric Power to individuals in rural regions, and

“(iii) a memorandum of comprehension with respect to this sort of joint use and development project is executed by a condition Office of transportation, such a county regional mass transit district along with a Local community redevelopment agency on or just before December 31, 1986, and

“(ii) entirely on account of conditions which, as determined by the Secretary of the Treasury or his delegate, will not be within the control of the lessor or lessee.

(ii) any transaction in between associates of precisely the same affiliated team through any taxable calendar year for which a consolidated return is produced by these types of team.

“(ii) Sizeable expenditures.— In the situation of facilities the first use of which commences While using the taxpayer and with respect to which sizeable expenditures are created just before January one, 1983, the amendments produced by this area shall not utilize with respect to these facilities on the extent such services are financed via the proceeds of an obligation issued exclusively to refund A further obligation which was issued prior to July 1, 1982.

“(II) any attain regarded by a tax-exempt entity on any disposition of the desire in such entity (and any dividend or interest received or accrued by a tax-exempt entity from such tax-exempt managed entity) shall be addressed as unrelated business enterprise taxable income for applications of portion 511.

For purposes of the subparagraph, the term ‘skilled container tools’ usually means any container, container chassis, or container trailer rico168 of a U . s . particular person with a current course lifetime of not a lot more than six a long time.