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TITLE 26-INTERNAL REVENUE CODE fer for the purpose of determining the amounts deductible under section 404 with re- spect to pension plans, employees' annuity plans, and stock bonus and profit-sharing plans. (12) Recovery of bad debts, prior taxes, or delin- quency amounts If the acquiring corporation is entitled to the recovery of bad debts, prior taxes, or de- linquency amounts previously deducted or credited by the distributor or transferor cor- poration, the acquiring corporation shall in- clude in its income such amounts as would have been includible by the distributor or transferor corporation in accordance with sec- tion 111 (relating to the recovery of bad debts, prior taxes, and delinquency amounts). (13) Involuntary conversions under section 1033 The acquiring corporation shall be treated as the distributor or transferor corporation after the date of distribution or transfer for purposes of applying section 1033. (14) Dividend carryover to personal holding compa- ny The dividend carryover (described in section 564) to taxable years ending after the date of distribution or transfer. (15) Indebtedness of certain personal holding com- panies The acquiring corporation shall be consid- ered to be the distributor or transferor corpo- ration for the purpose of determining the ap- plicability of subsection (c) of section 545, re- lating to deduction with respect to payment of certain indebtedness. (16) Certain obligations of distributor or transferor corporatioh, If the acquiring corporation- (A) assumes an obligation of the distribu- tor or transferor corporation which, after the date of the distribution or transfer, gives rise to a liability, and (B) such liability, if paid or accrued by the distributor or transferor corporation, would have been deductible in computing its taxable income, the acquiring corporation shall be entitled to deduct such items when paid or accrued, as the case may be, as if such corporation were the distributor or transferor corportion. A corporation which would have been an acquir- ing corporation under this section if the date of distribution or transfer had occurred on or after the effective date of the provisions of this subchapter applicable to a liquidation or reorganization, as the case may be, shall be entitled, even though the date of distribution or transfer occurred before such effective date, to apply this paragraph with respect to amounts paid or accrued in taxable years be- ginning after December 31, 1953, on account of such obligations of the distributor or trans- feror corporation. This paragraph shall not apply if such obligations are reflected in the amount of stock, securities, or property trans- ferred by the acquiring corporation to the transferor corporation for the property of the transferor corporation. (17) Deficiency dividend of personal holding com- pany If the acquiring corportion pays a deficien- cy dividend (as defined in section 547(d)) with respect to the distributor or transferor corpo- ration, such distributor or transferor corpora- tion shall, with respect to such payments, be entitled to the deficiency dividend deduction provided in section 547. (18) Percentage depletion on extraction of ores or minerals from the waste or residue of prior mining The acquiring corporation shall be consid- ered to be the distributor or transferor corpo- ration for the purpose of determining the ap- plicability of section 613(c)(3) (relating to ex- traction of ores or minerals from the ground). (19) Charitable contributions in excess of prior years' limitation Contributions made in the taxable year ending on the date of distribution or transfer and the 4 prior taxable years by the distribu- tor or transferor corporation in excess of the amount deductible under section 170(b)(2) for such taxable years shall be deductible by the acquiring corporation for its taxable years which begin after the date of distribution or transfer, subject to the limitations imposed in section 170(b)(2). In applying the preceding sentence, each taxable year of the distributor or transferor corporation beginning on or before the date of distribution or transfer shall be treated as a prior taxable year with reference to the acquiring corporation's tax- able years beginning after such date. [(20) Repealed. Pub. L. 94-455, title XIX, § 1901(a)(54), Oct. 4, 1976, 90 Stat. 1773] [(21) Repealed. Pub. L. 94-455, title XIX, § 1901(b)(16), Oct. 4, 1976, 90 Stat. 1796] (22) Successor insurance company If the acquiring corporation is an insurance company taxable under subchapter L, there shall be taken into account (to the extent proper to carry out the purposes of this sec- tion and of subchapter L, and under such reg- ulations as may be prescribed by the Secre- tary) the items required to be taken into ac- count for purposes of subchapter L in respect of the distributor or transferor corporation. (23) Credit under section 38 for investment in cer- tain depreciable property The acquiring corporation shall take into account (to the extent proper to carry out the purposes of this section and section 38, and under such regulations as may be prescribed by the Secretary) the items required to be taken into account for purposes of section 38 in respect of the distributor or transferor cor- poration (24) Crc*.c under section 40 for work incentive pro- gram expenses The acquiring corporation shall take into account (to the extent proper to carry out the purposes of this section and section 40, and under such regulations as may be prescribed by the Secretary) the items required to be taken into account for purposes of section 40 in respect of the distributor or transferor cor- poration. §381 Page 276