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TITLE 26-INTERNAL REVENUE CODE ciency established by a determination under this section, and all interest, additions to tax, additional amounts, or assessable penalties in respect thereof, shall be suspended for a period of 2 years after the date of the deter- mination. (2) Stay of collection In the case of any deficiency established by a determination under this section- (A) the collection of the deficiency, and all interest, additions to tax, additional amounts, and assessable penalties in respect thereof, shall, except in cases of jeopardy, be stayed until the expiration of 120 days after the date of the determination, and (B) if claim for a deficiency dividend de- duction is filed under subsection (e), the collection of such part of the deficiency as is not i educed by the deduction for deficien- cy dividends provided in subsection (a) shall be stayed until the date the claim is disal- lowed (in whole or in part), and if disal- lowed in part collection shall be made only with respect to the part disallowed. No distraint or proceeding in court shall be begun for the collection of an amount the col- lection of which is stayed under subpara- graph (A) or (B) during the period for which the collection of such amount is stayed. (g) Deduction denied in case of fraud No deficiency dividend deduction shall be al- lowed under subsection (a) if the determination contains a finding that any part of any defi- ciency attributable to an adjustment with re- spect to the taxable year is due to fraud with intent to evade tax or to willful failure to file an income tax return within the time pre- scribed by law or prescribed by the Secretary in pursuance of law. (h) Penalty For assessable penalty with respect to liability for tax of real estate investment trust which is allowed a deduc- tion under subsection (a), see section 6697. (Added Pub. L. 94-455, title XVI, § 1601(a)(1), Oct. 4, 1976, 90 Stat. 1742.) EFFECTIVE DATE Section 1608(a) of Pub. L. 94-455 provided that: "The amendments made by section 1601 [enacting sections 316(b)(3). 381(c)(25), 859, 6422(14), 6503()(5), and 6515(8) of this title, and amending section 857(b)(3)(C) of this title] shall apply with respect to determinations (as defined in section 859(c) of the In- ternal Revenue Code of 1954) [subsec. (c) of this sec- tion] occurring after the date of the enactment of this Act [Oct. 4, 1976]. If the amendments made by section 1601 apply to a taxable year ending on or before the date of enactment of this Act [Oct. 4, 1976]: "(1) the reference to section 857(b)(3)(A)(ii) [section 857(b)(3)(A)(ii) of this title] in sections 857(b)(3)(C) and 859(b)(1)(B) of such Code [sections 857(b)(3)(C) and 859(b)(1)(B) of this title] as amended; shall be considered to be a reference to section 857(b)(3)(A) of such Code [section 857(b)(3)(A) of this title], as in effect immediately before the enactment of this Act [Oct. 4, 1976], and "(2) the reference to section 857(b)(2)(B) [section 857(b)(2)(B) of this title] in section 859(a) of such Code, as amended [section 859(a) of this title], shall be considered to be a reference to section 857(b)(2)(C) of such Code [section 857(b)(2)(c) of this title], as in effect hmmediatley before the enactment of this Act [Oct. 4,1976]." SECTION REFERRED TO IN OTHER SECTIONS This section is referred to in sections 316, 381, 6422, 6515, 6697 of this title. § 860. Adoption of annual accounting period For purposes of this subtitle, a real estate in- vestment trust shall not change to or adopt any annual accounting period other than the calen- dar year. (Added Pub. L. 94-455, title XVI, § 1604(i)(1), Oct. 4, 1976, 90 Stat, 1752.) EFFECTIVE DATE Section effective Oct. 4, 1976, see section 1608(d) of Pub. L. 94-455 set out as an Effective Date of 1976 Amendment note under section 856 of this title. Subchapter N-Tax Based on Income From Sources Within or Without the United States Part I. Determination of sources of income. II. Nonresident aliens and foreign corporations. III. Income from sources without the United States. IV. Domestic international sales corporations.' V. International boycott determinations. AMENDMENTS 1976-Pub. L. 94-455, title X, § 1064(b), Oct. 4, 1976, 90 Stat. 1653, added item V. SUBCHAPTER REFERRED TO IN OTHER SECTIONS This subchapter is referred to in section 555 of this title. PART I-DETERMINATION OF SOURCES OF INCOME Sec. 861. Income from sources within the United States. 862. Income from sources without the United States. 863. Items not specified In section 861 or 862. 864. Definitions. PART REFERRED TO IN OTHER SECTIONS This part is referred to in sections 306, 901, 905, 931, 941, 7654 of this title. § 861. Income from sources within the United States (a) Gross income from sources within United States The following items of gross income shall be treated as income from sources within the United States: (1) Interest Interest from the United States or the Dis- trict of Columbia, and interest on bonds, notes, or other interest-bearing obligations of residents, corporate or otherwise, not includ- ing- (A) interest on amounts described in sub- section (c) received by a nonresident alien individual or a foreign corporation, if such interest is not effectively connected with the conduct of a trade or business within the United States, (B) interest received from a resident alien individual or a domestic corporation, when it is shown to the satisfaction of the Secre- tary that less than 20 percent of the gross income from all sources of such individual or such corporation has been derived from 'Part IV added by Pub. L. 92-178, title V, § 501, Dec. 10, 1971, 85 Stat. 535, without amending Subchapter N analysis to include such Part IV. § 860 Page 554