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TITLE 26-INTERNAL REVENUE CODE EFFECTIVE DATE OF 1976 AMENDMENT Amendment of subsec. (b) by section 1901(a)(7O)(A), (B), of Pub. L. 94-455 effective for taxable years begin- ning after Dec. 31, 1976, see section 1901(d) of Pub. L. 94-455, set out as an Effective Date of 1976 Amend- ment note under section 2 of this title. EFFECTIVE DATE OF 1969 AMENDMENT Amendment by Pub. L. 91-172 applicable with re- spect to net capital losses sustained in taxable years beginning after Dec. 31, 1969, see section 512(g) of Pub. L. 91-172, set out as an Effective Date of 1969 Amendment note under section 1212 of this title. EFFECTIVE DATE OF 1958 AMENDMENT Section 29(d) of Pub. L. 85-866 provided that: "(1) In general.-The amendments made by this sec- tion [amending subsec. (a)(2), (b)(1), (2), (3A), (4) to (6) of this section and adding section 381(c)(21) of this title] shall apply with respect to any change in a method of accounting where the year of the change (within the meaning of section 481 of the Internal Revenue Code of 1954 [this section]) is a taxable year beginning after December 31, 1953, and ending after August 16, 1954. "(2) Exception for certain agreements.-The amend- ments made by subsections (a), (b)(I), and (W) [amend- ing subsec. (a)(2) and (b)(4 to 6) of this section and adding section 381(c)(21) of this title] shall not apply if before the date of the enactment of this Act [Sept. 2, 1958]- "(A) the taxpayer applied for a change in the method of accounting in the manner provided by regulations prescribed by the Secretary of the Trea- sury or his delegate, and "(B) the taxpayer and the Secretary of the Trea. sury or his delegate agreed to the terms and condi- tions for making the change." ELECTION To RETUiR TO FORMER METHOD OF ACCOUNTING Section 29(e) of Pub. L. 85-866 authorized an elec- tion by certain taxpayers, who, for any taxable years beginning after Dec. 31, 1953, and ending after Aug. 16, 1954, and before Sept. 2, 1958, computed their tax- able incomes using different accounting methods in succeeding taxable years, to return to their first method of accounting, where the election was made within six months after Sept. 2, 1958. Claims for re- funds of overpayments of tax resulting from the elec- tion were to be filed within one year after the date of the election. Such an election was to be considered a consent to an assessment of a deficiency resulting from the election, where the assessment is made within one year after the date of the election. TRANSITIONAL PROVISIONS FOR INCOME TAX TREATMENT OF DEALE REsERVE INCOME Pub. L. 86-459, May 13, 1960, 74 Stat. 124, authorized any person who computed taxable income under the accrual method of accounting for his most recent tax- able year ending on or before June 22, 1959, and who treated dealer reserve income for such taxable year as accruable for a subsequent taxable year, to elect before Sept. 1, 1960, to have section 481 of this title apply to the treatment for income tax purposes of dealer reserve income. SECTION REFERRED TO IN OTHER SECTIONS This section is referred to in sections 463, 1251 of this title; title 42 section 401. § 482. Allocation of Income and deductions among taxpayers In any case of two or more organizations, trades, or businesses (whether or not incorpo- rated, whether or not organized in the United States, and whether or not affiliated) owned or controlled directly or indirectly by the same in- terests, the Secretary may distribute, appor- tion, or allocate gross income, deductions, cred- its, or allowances between or among such orga- nizations, trades, or businesses, if he determines that such distribution, apportionment, or allo- cation is necessary In order to prevent evasion of taxes or clearly to reflect the Income of any of such organizations, trades, or businesses. (Aug. 16, 1954, ch. 736, 68A Stat. 162; Oct. 4, 1976, Pub. L. 94-455, title XIX, § 1906(b)(13)(A), 90 Stat. 1834.) AMENDMENTS 1976-Pub. L. 94-455 struck out "or his delegate" fol- lowing "Secretary". SECTION REFERRED TO IN OTHER SECTIONS This section is referred to in sections 994, 1505 of this title. § 483. Interest on certain deferred payments (a) Amount constituting interest For purposes of this title, In the case of any contract for the sale or exchange of property there shall be treated as interest that part of a payment to which this section applies which bears the same ratio to the amount of such payment as the total unstated interest under such contract bears to the total of the pay- ments to which this section applies which are due under such contract. (b) Total unstated interest For purposes of this section, the term "total unstated interest" means, with respect to a con- tract for the sale or exchange of property, an amount equal to the excess of- (1) the sum of the payments to which this section applies which are due under the con- tract, over (2) the sum of the present values of such payments and the present values of any inter- est payments due under the contract. For purposes of paragraph (2), the present value of a payment shall be determined, as of the date of the sale or exchange, by discounting such payment at the rate, and in the manner, provided in regulations prescribed by the Secre- tary. Such regulations shall provide for dis- counting on the basis of 6-month brackets and shall provide that the present value of any in- terest payment due not more than 6 months after the date of the sale or exchange is an amount equal to 100 percent of such payment. (c) Payments to which section applies (1) In general Except as provided in subsection (f), this section shall apply to any payment on ac- count of the sale or exchange of property which constitutes part or all of the sales price and which is due more than 6 months after the date of such sale or exchange under a contract- (A) under which some or all of the pay- ments are due more than one year after the date of such sale or exchange and (B) under which, using a rate provided by regulations prescribed by the Secretary for purposes of this subparagraph, there is total unstated interest. 71-999 0 - 78 - 28 (Vol. 7) Page 373 § 483