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RULES AND REGULATIONS

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CONTENTS Continued
FED ER ALlpEG ISTER
Omta
Interior Department
PaS

See Geological Survey; Indian Af fairs Bureau.
Internal Revenue Bureau
Published daily, except Sundays, Mondays, and days following official Federal holidays, by the Division of the Federal Register, the National Archives, pursuant to the authority contained in the Federal Register Act, ap proved July 26, 1935 49 Stat. 500, as amended; 44 U. S. C ch. 8B , under regula tions prescribed by the Administrative Com mittee, approved by the President. Distribu tion is made only by the Superintendent of Documents, Government Printing Office, Washington 25, D. C.
The regulatory material appearing herein Is keyed to the Code of Federal Regulations, which is published, under 50 titles, pursuant to section 11 of the Federal Register Act, as amended June 19, 1937.
The F ederal R egister will be furnished by mail to subscribers, free of postage, for $1.50
per month or $15.00 per year, payable in ad vance. The charge for individual copies minimum 151 varies in proportion to the size of the issue. Remit check or money order, made payable to the Superintendent of Documents, directly to the Government Printing Office, Washington 25, D. C.
There are no restrictions on the republicatlon of material appearing in the F ederal R egister .

Rules and regulations:
Income tax, taxable years begin ning after Dec. 31,1941; Fed eral duties and excise taxes
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Justice Department
See Alien Property, Office of.
Labor Department Securities and Exchange Com mission
Notices:
Hearings, etc.:
Cain, Wofford___________ - . 951
Delaware Power and lig h t Co. 950
High Divide Mining Co . 949
Kings County Lighting Co 949
Moor, Lee._________
951
Murchison, Clint W., J r -----951
Murchison, John Dabney----- 951
Ohio Power Co. and West Penn Power Co-------------952
Pennsylvania Electric Co. et a l ______________
950
Thomson Divide Mining Co_ 949
Union Producing Co---------950
Notices:
Relinquishment of control over certain property of former German Government---------

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Treasury Department
CODE OF FEDERAL
REGULATIONS

See Customs Bureau; Internal Revenue Bureau.

The Code of Federal Regulations, 1949 Edition, contains a codifi cation of Federal administrative rules and regulations issued on or before December 31, 1948, and in effect as to facts arising on or after January 1, 1949.

Rules and regulations:
General provisions; uniforms for guards__________ ____

The following book is now available:

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Wage and Hour Division
Proposed rule making:
Puerto Rico; home"workers in needlework industries Corr. _______ _________ _

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CODIFICATION GUIDE

Title 3, 1948 Supplement, con taining the full text of Presiden tial documents issued during 1948, with appropriate reference tables and index.
This book may be obtained from the Superintendent of Documents, Govern ment Printing Office, Washington 25, D. C , at $2.75 per copy.

A numerical list of the parts of the Code of Federal Regulations affected by documents published in this issue. Proposed rules, as opposed to final actions, are identified as such.

Title 14

Chapter I:
Part 42 proposed_________
Part 45 proposed________ -

Page
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943

Title 19

Chapter I:
Part 11____ _________ ___

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Title 25

Chapter I:
Part 130proposed_________

CONTENTS Continued Industry Cooperation, of Continued
Office
NoticesContinued Voluntary steel allocation plan;
hearingsContinued Economic Cooperation Ad ministration countries----Federal reclamation projects.
Warm air heating equipment for residential housing
Pa&e

See Wage and Hour Division.

Veterans Administration
In computing net ipcome there shall be allowed as deductions:

c Taxes generally 1 Allowance in general. Taxes paid or accrued within the taxable year, except
State Department
7949 Edition
The following statement Is published pursuant to section 8 A 3 of the Administrative Procedure Act:
Reference is made to that portion of section 23 c of the Internal Revenue Code, as amended by section 111 of the Revenue Act of 1943, enacted February 25, 1944, which provides that:

Title 26

i Chapter I:
Part 29__ ____ . . . _________

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Title 29

Chapter V:
Part 545proposed__________

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945 Title 38
Chapter I:
945 Part 1_____________________

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F Federal import duties, and Federal ex cise and stamp taxes not described in subparagraph A, B, D, or E , but this subsection shall not prevent such duties and taxes from being deducted under subsec tion a.

On the basis of the foregoing, this office issued a ruling designated as I. T.
3806 C. B. 1946-2, 41 which reads, in part, as follows:
3 Federal stamp taxes paid by a corpo ration on the issuance of its bonds upon original financing or refinancing, are ex;
haustlble capital expenditures, amortizable over the term or life of the bonds;

It has come to the attention of this office that prior to the publication of I. T. 3806 certain corporate taxpayers which paid Federal stamp taxes on the issuance of bonds deducted the entire amounts so paid on their Federal income and excess profits tax returns under the assumption th at such taxes were de ductible as ordinary $nd necessary busi ness expenses under the provisions of section 23 a of the Internal Revenue Code. It appears that retroactive appli cation of the ruling quoted above would create, in these instances, considerable hardship.
Accordingly it will be the administra tive policy not to disturb such treat ment, with respect to returns filed for taxable years ending prior to the publi cation of I. T. 3806, where Federal stamp taxes paid by a corporation on the issu ance of its bonds were deducted in their entirety in tlie year of payment or ac crual. See section 3791 b of the Inter nal Revenue Code; 26 U. S. C. 3791 b.
Inasmuch as the rule announced here in merely limits the effective date of ap plication of a previous ruling, and the needs of certain of the taxpayers af fected thereby require immediate issu ance of the rule, prior notice and public rule-making procedure in connection therewith are hereby found to be im practicable, as they would delay promul gation of the rule.
As this mimeograph is within the par enthetical, exception to section 4 c of the Administrative Procedure Act, it shall be effective upon its filing for pub lication in the F ederal R egister.
Correspondence relating to this mim eograph should refer to Its number and the symbols IT:EIM.
seal
F red S. M artin,
Acting Commissioner.
Approved: February 23, 1949.
T homas J. Lynch ,
Acting Secretary of the Treasury.
F. R. Doc. 49-1546; Filed, Mar. 1, 1949;
8:49 a. m.
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