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INCOME TAX PROJECT i (GAINS AND LOSSES IN RESPECT TO PROPERTY, December 7, 1949)

handle is hein.ali/aliftp0023 and id is 1 raw text is: MaTMs-ITY Or. CAL1i1UTWIA

School of Jurisprudemce
Berkeloy 4, California                                      Decenber 7, 1949
To the rcnmbera of the Policy Committee on Taxatini
Enclosed is a copy of the initial provisions regarding gain
and loss on tbo disponition of proparty, and caital gains and
losses. They represent a mvivion of co responding portions of
Preliminary Draft No. 22. The Oomcrim  for these noctlons to-
gather vwith slight rvisicns tmd iZ3 bult:flcO of Freliiatiary Draft
11o. 22 are being prapred for  iTh      n Wi ) mteal to bo
printed for distribution in Jvur, Tfiis cpocail eniclolou1. ic
beinig sent at this time to ini-.cato : natvuro of the rivision
disusmed and tentatively nirvor   upon ;:e u o lta  1iot z . T.)hv
min pux-pose of this revision U- to restaict the scope of tbo
term disposition. ThIs has boon done by conftnin   section NZC.
to the traditional scope of sc3tion III and by writing the
dofir lton of capital gains and lossaes in section X225(a) in
such a fashion that it does nob turn upon the presence of a
disposition. Such olilnation of dispoition from the capital
gain and loss definition elinnatea the need for a definition
of disposition and for the stress placed upon the tmm in Pro-
lim-nnX1 Draft No. 22.
Str=leCy S. %Urr43y
SSSino
Pino.

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