26 U.S.C. § 114: Repealed. Pub. L. 108–357, title I, § 101(a) , Oct. 22, 2004 , 118 Stat. 1423 ]

In the case of transactions during 2005 or 2006, the amount includible in gross income by reason of the amendments made by this section [amending sections 56, 275, 864, 903, and 999 of this title and repealing this section and sections 941 to 943 of this title] shall not exceed the applicable percentage of the amount which would have been so included but for this subsection. For 2005, the applicable percentage shall be 20 percent. For 2006, the applicable percentage shall be 40 percent. This subsection shall be applied without regard to any deduction allowable under section 199 [probably means former section 199 of the Internal Revenue Code of 1986]. was treated as transferred under clause (i) thereof, or was acquired during a taxable year to which such election applies and before May 1, 2003 , in the ordinary course of its trade or business. Repealed. Pub. L. 109–222, title V, § 513(b) , May 17, 2006 , 120 Stat. 366 .]”