Taxable Years Beginning in 1940 (B) Its highest bracket amount for the taxable year after the ex change, multiplied by the number of days in the taxable year remain ing after the day of the exchange, divided by the number of days in the taxable year. See. 752. (b) (2) Taxable years after exchange involving control. its In the case of a transferor upon an exchange after the beginning of ito first taxable year under this subchapter, if immediately after the exchange the transferor or shareholdere, or both, are in control of the transferee, the transferor's highest bracket amount for any taxable year after the taxable year in which the exchange takes place shall be an amount which is a percentage of its highest bracket amount im mediately preceding the exchange equal to the percentage which ite daily invested capital for the day after the exchange is of its daily invested capital for the day of the *rchange. Sec. 752. (b) (3) Taxable years after exchange not involving control In the case of a transforor upon an exchange (other than a transferor described in paragraph (4) of this cubsection) after the beginning of its first taxable year under this subchapter, if immediately after the exchange no trano feror or its shareholders, or both, upon the exchange are in control of the transferee, and if the share holders of the transforce immedi ately preceding the exchange are not in control of the transferee im mediately after the exchange, the transferor's highest bracket amount for any taxable year after the ex change shall be the excess, if any, of the sum of the transferor's high est bracket amount immediately preceding the exchange and the transferee's highest bracket amount immediately preceding the exchange, over $500,000 See. 752. (b) (4) Taxable years after certain exchanges under seetion 112 (b) (5). In the case of an exchange after the beginning of the first taxable year under this subchapter of any transferor or transforce upon such exchange, in volving two or more transferors, or one or more transferors and one or more other persons, if immediately Taxable Years See. 752. (e) Highest bracket amount of transferee. See, 752, (e) (1) Taxable year of exchange involving control. after the exchange no one of such after the exchange no one of such (B) Plus an amount which bears (B) Plus an amount which bears the same ratio to the exeen over the same ratio to the excess ore $500,000 of the sum of the amounts $500,000 of the sum of the amounts computed under subparagraph (A) computed under cubparagraph (A) with respect to each transferor, as with respect to each transferor, as the amount computed under sub the amount computed under sub paragraph (A) with respect to such |paragraph (A) with respect to such transferor bears to the sum of the transferor bears to the sum of the mounts computed under such sub- amounts computed under such cub paragraph with respect to each paragraph with respect to each transferor: See. 752. (e) Highest bracket amount of transferee. transferor: See, 752. (e) Highest bracket amount of transferee. See. 752. (e) (1) Taxable year of Sec. 752, (c) (1) Taxable year of exchange involving control. In exchange involving control. In the ease of a transferee upon an the case of a transferee upon on exchange after the beginning of the exchange after the beginning of the firet taxable year under this sub first taxable year under this cub chapter of a transferor upon such chapter of a transferor upon such exchange the transferee's highest exchange the transferee's highest bracket amount for the taxable year in which the exchange takes place shall be the sum of (A) I highest bracket amount immediately preceding the exchange multiplied by the number of days in the taxable year up to and in eluding the day of the exchange, plus (B) Its highest bracket amount for the taxable year after the ex change multiplied by the number of days in the taxable year remaining after the day of the exchange, bracket amount for the taxable year in which the exchange takes place shall be the sum of (A) Ito highest bracket amount immediately preceding the exchange multiplied by the number of days in the taxable year up to and in cluding the day of the_exchange, plus (B) Its highest bracket amount for the taxable year after the ex change multiplied by the number of days in the taxable year remaining after the day of the exchange, divided by the number of days in divided by the number of days in the taxable year. For the purposes the taxable year. For the purposes of this paragraph and subsection of this paragraph and subsection (d) of this section "exchange" in (d) of this section "exchange" in Taxable Years Beginning in 1940 after the exchange no one of such transferors, or its shareholders, or both, and no one or more of ouch other persons are in control of the transferee and if such exchange is an exchange described in oootion 112 (b) (5) or so much of section 112 (e) or 112 (o) as refers to see tion 112 (b) (5), the highest bracket amount of any ouch trangforor for any taxable year after the orehango shall be an amount equal to its highest bracket amount immediately preceding the exchange (4) Minus an amount which bears the same ratio to its highest bracket amount immediately pro eeding the exchange as the of its daily invested capital for the day of the exchange over its daily invested capital for the day after the exchange bears to its daily in vested capital for the day of the ex change, and (B) Plus an amount which bears the same ratio to the erecss over $500,000 of the sum of the amounts computed under subparagraph (A) with respect to each transferor, as the amount computed under sub paragraph (A) with respect to such transferor bears to the sum of the amounte computed under such sub paragraph—with respect to each transferor, See. 752. (e) Highest bracket amount of transferee. See. 758. (e) (1) Taxable year of exchange involving control. In the case of a transferee upou an exchange after the beginning of the first tarable year under this sub chapter of a transferor upon such exchange the transferee's highest bracket amount for the tarable-year in which the exchange takes place shall be the sum of (4) Its highest bracket amount immediately preceding the exchange multiplied by the number of days in the taxable year up to and in cluding the day of the exchange, plus (B) Its highest bracket amount for the taxable year after the ex change multiplied by the number of days in the taxable year remaining after the day of the exchange, divided by the number of days in the taxable year. For the purposes of this paragraph and subsection (d) of this section “exchange" in Taxable Years See. 752. (e) (2) Taxable years after exchange involving control. See. 752. (e) (3) Taxable years after exchange not involving con trol. See. 759. (e) (4) Taxable years after certain exchanges under see tion 112 (b) (5). eludes a liquidation described in eludes a liquidation described in See. 759. (e) (2) Taxable years See. 758. (e) (2) Taxable years after exchange involving control. after exchange involving control In the case of a transferee upon an In the case of a transferee upon an exchange after the beginning of the exchange after the beginning of the first taxable year under this sub first taxable year under this sub chapter of a transferor upon such chapter of a transferor upon such exchange, if immediately after the exchange, if immediately after the exchange any transferor upon such exchange any transferor upon such exchange or its shareholders, or exchange or its shareholders, or hoth, are in control of the trans- both, are in control of the trane feree, the transferee's highest feree, the transferee's highest bracket amount for any taxable bracket amount for any taxable year after the exchange shall be an year after the exchange shall be on amount which is a percentage of amount which is a percentage of such transferor's highest bracket such transferor's highest bracket amount immediately preceding the amount immediately preceding the exchange equal to the percentage exchange equal to the percentage which the excess of the transferee's which the excess of the transferce's daily invested capital for the day daily invested capital for the day after the exchange over its daily in after the exchange over its daily in vested capital for the day of the vested capital for the day of the exchange is of such transferor's exchange is of such transferor's daily invested capital for the day daily invested capital for the day of the exchange. of the exchange. See. 752. (e) (3) Taxable years Bee. 758. (e) (8) Taxable years after exchange not involving con- after exchange not involving con trol. In the case of a transferee trol. In the case of a transferes upon an exchange (other than a upon an exchange (other than transferee described in paragraph transferee described in paragraph (4) of this subsection) after the (4) of this subsection) after the beginning of the first taxable year beginning of the first taxable year under this subchapter of a trans under this subchapter of a trans feror upon such exchange, if im feror upon such exchange, if im mediately after the exchange no mediately after the exchange to transferor or its shareholders, or transferor or its shareholders, er both, are in control of the trans both, are in control of the tram feree, and if the shareholders of the feree, and if the shareholders of the transferee immediately preceding transferee immediately preceding the exchange are not in control of the exchange are not in control of the transferee immediately after the transferee immediately after the exchange, the transferee's high est bracket amount for any taxable year after the exchange shall be an amount equal to (A) the sum of the transferor's highest bracket amount immediately preceding the exchange and the transferee's highest bracket amount immediately preceding the exchange, or (B) $500,000, which ever is the smaller. the exchange, the transferee's high est bracket amount for any taxable year after the exchange shall be an amount equal to (A) the sum of the transferor's highest bracket amount immediately preceding the exchange and the transferee's highest bracket amount immediately preceding the exchange, or (B) $500,000, which ever is the smaller. See. 759. (e) (4) Taxable years See, 752, (e) (4) Taxable years after certain exchanges under see after certain exchanges under see tion 112 (b) (5). In the case of an tion 112 (b) (5). In the case of an exchange described in subsection exchange described in subsection (b) (1) of this section, the highest | (b) (4) of this section, the highest bracket amount of the transferee | bracket amount of the transferee Taxable Years Beginning in 1940 eludes a liquidation described in paragraph (5) of this subsection, and such exchange shall be deemed to have taken place on the day such liquidation was completed. See. 752. (e) (2) Taxable years after exchange involving control. In the case of a transferee upon an exchange after the beginning of the first taxable year under this sub chapter of a transferor upon suck exchange, if immediately after the exchange any transferor upon such exchange or its shareholders, or both, are in control of the trano feree, the transferee's highest bracket amount for any taxable year after the exchange shall be an amount which is a percentage of such transferor's highest bracket amount immediately preceding the exchange equal to the percentage which the excess of the transferee's daily invested capital for the day after the exchange over ite daily in vested capital for the day of the exakange is of such transferor's daily invested capital for the day of the exchange. See. 752. (e) (3) Taxable years after exchange not involving control In the case of a transferee upon an exchange (other than a transferee described in paragraph (1) of this subsection) after the beginning of the first taxable year under this subchapter of a transferor upon such exchange, if im mediately after the exchange no transferor or its shareholders, or both, are in control of the transferee, and if the shareholders of the traneforce immediately preceding the exchange are not in control of the transferee immediately after the exchange, the transferee's high est bracket amount for any tarable year after the exchange shall be an amount equal to (4) the sum of the transferor's highest bracket amount immediately preceding the exekango and the transferee's highest bracket amount immediately preceding the exchange, or (B) $500,000, which over is the smaller. See. 752. (e) (4) Taxable years after certain exchanges under seetion 112 (b) (5). In the case of an exchange described in subsection (b)(1) of this section, the highest bracket amount of the transferee |