26 U.S.C. § 196 - Deduction for certain unused business credits
26 USC 196 - Deduction for certain unused business credits
(a) Allowance of deduction
If any portion of the qualified business credits determined for any taxable year has not, after the application of section 38 (c), been allowed to the taxpayer as a credit under section 38 for any taxable year, an amount equal to the credit not so allowed shall be allowed to the taxpayer as a deduction for the first taxable year following the last taxable year for which such credit could, under section 39, have been allowed as a credit.
If any portion of the qualified business credits determined for any taxable year has not, after the application of section 38 (c), been allowed to the taxpayer as a credit under section 38 for any taxable year, an amount equal to the credit not so allowed shall be allowed to the taxpayer as a deduction for the first taxable year following the last taxable year for which such credit could, under section 39, have been allowed as a credit.
(b) Taxpayer’s dying or ceasing to exist
If a taxpayer dies or ceases to exist before the first taxable year following the last taxable year for which the qualified business credits could, under section 39, have been allowed as a credit, the amount described in subsection (a) (or the proper portion thereof) shall, under regulations prescribed by the Secretary, be allowed to the taxpayer as a deduction for the taxable year in which such death or cessation occurs.
If a taxpayer dies or ceases to exist before the first taxable year following the last taxable year for which the qualified business credits could, under section 39, have been allowed as a credit, the amount described in subsection (a) (or the proper portion thereof) shall, under regulations prescribed by the Secretary, be allowed to the taxpayer as a deduction for the taxable year in which such death or cessation occurs.
(c) Qualified business credits
For purposes of this section, the term qualified business credits means
For purposes of this section, the term qualified business credits means
(1) the investment credit determined under section 46 (but only to the extent attributable to property the basis of which is reduced by section 50 (c)),
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(4) the research credit determined under section 41 (a) (other than such credit determined under section 280C (c)(3)) for taxable years beginning after December 31, 1988,
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(d) Special rule for investment tax credit and research credit
Subsection (a) shall be applied by substituting an amount equal to 50 percent of for an amount equal to in the case of
Subsection (a) shall be applied by substituting an amount equal to 50 percent of for an amount equal to in the case of
(1) the investment credit determined under section 46 (other than the rehabilitation credit), and