Taxable Years Beginning in 1945 Sec. 127. (c) (2) Amount of gain includible. Same as 1944. Taxable Years Beginning in 1944 the amount of such recovery shall be included in gross income to the extent provided in paragraph (2). Sec. 127. (c) (2) Amount of gain includible.-The amount of the recovery of any money or property in respect of property considered under subsection (a) as destroyed or seized shall be an amount equal to the aggregate of such money and the fair market value of such property, determined as of the date of the recovery. To the extent that such amount plus the aggregate of the amounts of previous such recoveries do not exceed that part of the aggregate of the allowable deductions in prior taxable years on account of the destruction or seizure of property described in subsection (a) which did not result in a reduction of any tax of the taxpayer under this chapter, such amount shall not be includible in gross income and shall not be deemed gain upon the involuntary conversion of property as a result of its destruction or seizure. To the extent that such amount plus the aggregate of the amounts of previous such recoveries exceed that part of the aggregate of such deductions which did not result in a reduction of any tax of the taxpayer under this chapter and do not exceed that part of the aggregate of such deductions which did result in a reduction of any tax of the taxpayer under this chapter, such amount shall be included in gross income but shall not be deemed a gain upon the involuntary conversion of property as a result of its destruction or seizure. To the extent that such amount plus the aggregate of the amounts of previous such recoveries exceed the aggregate of the allowable deductions in prior taxable years on account of the destruction or seizure of property described in subsection (a), such amount shall be considered a gain upon the involuntary conversion of property as a result of its destruction or seizure and shall be recognized or not recognized as provided in section 112 (f). If for any previous taxable year the taxpayer chooses under subsection (b) to treat any obligations and liabilities as discharged or satisfied out of the property or Taxable Years Beginning before 1944 Sec. 127. (c) (2) Amount of gain includible. Section originated 1942 as Sec. 127 (c) (2), I. R. C., and was made retroactive to 1941. For any amendments prior to 1944, see Ninth Edition, p. 369. Taxable Years interest described in subsection (a), and if such obligations and liabilities were not so discharged or satisfied, the amount of such obligations and liabilities treated as discharged or satisfied under subsection (b) shall be considered for the purposes of this section as a deduction by reason of this section which did not result in a reduction of any tax of the taxpayer under this chapter. For the purposes of this paragraph an allowable deduction for any taxable year on account of the destruction or seizure of property described in subsection (a) shall, to the extent not allowed in computing the tax of the taxpayer for such taxable year, be considered an allowable deduction which did not result in a reduction of any tax of the taxpayer under this chapter. Taxable Years Same as 1944. Sec. 127. (c) (3) Restoration of Sec. 127. (c) (3) Restoration of value of investments referable value of investments referable to destroyed or seized property. to destroyed or seized property. -For the purposes of paragraphs (1) and (2), the restoration in whole or in part of the value of any interest described in subsection (a) (3) by reason of any recovery of money or property in respect of property to which such interest related and which was considered under subsection (a) (1) or (2) as destroyed or seized shall be deemed a recovery of property in respect of property considered under subsection (a) as destroyed or seized. Sec. 127. (d) Basis of recovered Sec. 127. (d) Basis of recovered property. The unadjusted basis of property. property recovered in respect of property considered destroyed or seized under subsection (a) shall be determined under this subsection. Such basis shall be an amount equal to the fair market value of such property, determined as of the date of the recovery, reduced by an amount equal to the excess of the aggregate of such fair market value and the amounts of previous recoveries of money or property in respect of property considered under subsection (a) as destroyed or seized over the aggregate of the allowable deductions in prior taxable years on account of the destruction or seizure of property described in subsection (a), and increased by that portion of the amount of the Same as 1944. Taxable Years Beginning in 1946 and 1947 Sec. 127. (c) (3) Restoration of value of investments referable to destroyed or seized property. Same as 1944. Sec. 127. (d) Basis of recovered property. Same as 1944. Taxable Years Sec. 127. (c) (3) Restoration of value of investments referable to destroyed or seized property. Same as 1944. Sec. 127. (d) Basis of recovered property. Same as 1944. Taxable Years interest described in subsection Taxable Years Beginning before 1944 Sec. 127. (c) (3) Restoration of Sec. 127. (c) (3) Restoration of value of investments referable value of investments referable to destroyed or seized property. to destroyed or seized property. -For the purposes of paragraphs (1) and (2), the restoration in Sec. 127. (d) Basis of recovered property.-The unadjusted basis of property recovered in respect of property considered destroyed or seized under subsection (a) shall be determined under this subsection. Such basis shall be an amount equal to the fair market value of such property, determined as of the date of the recovery, reduced by an amount equal to the excess of the aggregate of such fair market value and the amounts of previous recoveries of money or property in respect of property considered under subsection (a) as destroyed or seized over the aggregate of the allowable deductions in prior taxable years on account of the destruction or seizure of property described in subsection (a), and increased by that portion of the amount of the Section originated 1942 as Sec. 127 (c) (3), I. R. C., and was made retroactive to 1941. For any amendments prior to 1944, see Ninth Edition, p. 370. Sec. 127. (d) Basis of recovered property. Section originated 1942 as Sec. 127 (d), I. R. C. For any amendments prior to 1944, see Ninth Edition, p. 370. Taxable Years Beginning in 1949 recovery which under subsection (c) is treated as a recognized gain from the involuntary conversion of property. Upon application of the taxpayer, the aggregate of the bases (determined under the preceding sentence) of any properties recovered in respect of properties considered under subsection (a) as destroyed or seized may be allocated among the properties so recovered in such manner as the Commissioner may determine under regulations prescribed by him with the approval of the Secretary, and the amounts so allocated to any such property so recovered shall be the unadjusted basis of such property in lieu of the unadjusted basis of such property determined under the preceding sen tence. Sec. 127. (e) Partial worthlessness of certain investments in destroyed or seized property. Sec. 127. (e) (1) Destruction or seizure of investment.-If a taxpayer owns not less than 50 per centum of each class of stock of a corporation, if such corporation has property described in subsection (a) (1) or (2) deemed to be destroyed or seized, the adjusted basis for determining loss of which is at least 75 per centum of the adjusted basis for determining loss of all such corporation's property, and if such corporation completely liquidates (by distributing all the assets which it is able to distribute and all its rights to assets which it is not able to distribute, including the right to the recovery of the property described in subsection (a) (1) and (2)) within one year after such property is deemed to be destroyed or seized, or within six months after the date of the enactment of the Revenue Act of 1942 whichever is the later, then that part of the loss by the taxpayer on such liquidation which would be attributable to the destruction or seizure of such property, as established to the satisfaction of the Commissioner, shall be treated for the purposes of this chapter as a loss by the taxpayer upon the destruction or seizure of the part of the stock or other interest of the taxpayer to which such Taxable Years Sec. 127. (e) Partial worthlessness of certain investments in destroyed or seized property. Sec. 127. (e) (1) Destruction or seizure of investment. Same as 1944. Taxable Years recovery which under subsection Sec. 127. (e) Partial worthlessness of certain investments in destroyed or seized property. Taxable Years Beginning before 1944 Sec. 127 (e) Partial worthlessness of certain investments in destroyed or seized property. Section originated 1942 as Sec. 127 (e) (1), I. R. C., and was made retroactive to 1941. For any amendments prior to 1944, see Ninth Edition, p. 371. Sec. 127. (e) (1) Destruction or Sec. 127. (e) (1) Destruction seizure of investment.-If a tax- or seizure of investment. payer owns not less than 50 per centum of each class of stock of a corporation, if such corporation has property described in subsection (a) (1) or (2) deemed to be destroyed or seized, the adjusted basis for determining loss of which is at least 75 per centum of the adjusted basis for determining loss of all such corporation's property, and if such corporation completely liquidates (by distributing all the assets which it is able to distribute and all its rights to assets which it is not able to distribute, including the right to the recovery of the property described in subsection (a) (1) and (2)) within one year after such property is deemed to be destroyed or seized, or within six months after the date of the enactment of the Revenue Act of 1942, whichever is the later, then that part of the loss by the taxpayer on such liquidation which would be attributable to the destruction or seizure of such property, as established to the satisfaction of the Commissioner, shall be treated for the purposes of this chapter as a loss by the taxpayer upon the destruction or seizure of the part of the stock or other interest of the taxpayer to which such |