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1974/10/29 HR12281 Extension of Copper Duty Suspension
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1974/10/29 HR12281 Extension of Copper Duty Suspension
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The original documents are located in Box 13, folder "1974/10/29 HR12281 Extension of Copper Duty Suspension" of the White House Records Office: Legislation Case Files at the Gerald R. Ford Presidential Library. Copyright Notice The copyright law of the United States (Title 17, United States Code) governs the making of photocopies or other reproductions of copyrighted material. Gerald R. Ford donated to the United States of America his copyrights in all of his unpublished writings in National Archives collections. Works prepared by U.S. Government employees as part of their official duties are in the public domain. The copyrights to materials written by other individuals or organizations are presumed to remain with them. If you think any of the information displayed in the PDF is subject to a valid copyright claim, please contact the Gerald R. Ford Presidential Library. Exact duplicates within this folder were not digitized. Digitized from Box 13 of the White House Records Office Legislation Case Files at the Gerald R. Ford Presidential Library APPROVED OCT 29 1974 THE WHITE HOUSE ACTION WASHINGTON Last day - Tuesday, October 29 October 26, 1974 Posted 10/29 TORRELLIVES MEMORANDUM FOR THE PRESIDENT FROM: KEN COLE SUBJECT: Enrolled Bill: Extension of Copper Duty Suspension, H.R. 12281 BACKGROUND The suspension of duties on certain forms of copper expired on June 30 of this year. This bill would reimpose the suspension until June 30, 1975, and make it retroactive to when the suspension expired. All your advisers support the suspension due to a domestic shortage of copper. Congress attached to this otherwise desirable bill a rider which would provide tax relief of nearly $1.4 million for a private corporation, State Lines, Incorporated, by permitting it to treat as a deduction a damage payment made in 1959. The payment was made pursuant to a court decision based on cargo which was lost by a liquidated corporation acquired by State Lines. ARGUMENTS FOR SIGNING Because of the copper shortage, there is a legitimate need for the duty suspension. There are equitable considerations which could justify the tax relief. ARGUMENTS FOR VETO The tax rider involves an undesirable precedent by providing special relief from the tax laws for a corporation which made a calculated business decision that turned out to be the wrong choice. Further, this involves a potential revenue loss of $1.4 million for the govern- ment. Congress can easily reenact the copper duty suspension as a clean bill when it returns from its recess. (You can encourage Congress to take this action and indicate your support for the duty suspension by signing, the attached veto statement.) FORD i LIBRARY GERALD 2 STAFF AND AGENCY POSITIONS The following recommend signature: Department of the Interior Department of Treasury (objects to the tax rider but avoids a veto recommendation because of the merits of the copper duty suspension) The following recommend veto and a statement which urges Congress to pass a clean copper duty suspension bill: Roy Ash (see attached enrolled bill memo) Ken Cole Bill Timmons Phil Areeda DECISION H.R. 12281 Sign (Tab A) Veto SR7. (sign veto message reviewed by Paul Theis at Tab B) APPROVED EXECUTIVE OFFICE OF THE PRESIDENT OFFICE OF MANAGEMENT AND BUDGET WASHINGTON, D.C. 20503 OCT 24 1974 MEMORANDUM FOR THE PRESIDENT Subject: Enrolled Bill H.R. 12281 - Extension of copper duty suspension Sponsor - Rep. Griffiths (D) Michigan Last Day for Action October 29, 1974 - Tuesday Purpose Continues through June 30, 1975, the suspension of duties on certain forms of copper; and contains a tax rider relating to the basis of property received in liquidations. Agency Recommendations Office of Management and Budget Disapproval (veto message attached) Department of the Treasury Does not recommend disapproval Department of State No objection Department of Labor No objection Department of Commerce No objection (sections 1 and 2) Office of the Special Representative for Trade Negotiations No objection (sections 1 and 2) Council on International Economic Policy No objection (sections 1 and 2) Department of the Interior Approval Discussion The enrolled bill contains the following provisions: Extension of copper duty suspension (sections 1 and 2) Except for a period of one year, the duty on copper ore and articles was suspended from 1966 until June 30, 1974. This 2 suspension reflected the shortage of domestic copper pro- duction as compared to demand except during the year July 1, 1972 to July 1, 1973 when shortages and prices were reduced to the point at which a duty suspension was not considered necessary. The generally prevailing situation of excess domestic demand over supply currently exists, and, accordingly, H.R. 12281 would continue, until June 30, 1975, the past duty- free treatment of copper ore and articles. Such treatment would be made effective as of July 1, 1974 and be extended to imports from countries enjoying most-favored-nation status. In its report on H.R. 12281, the Senate Finance Committee notes: "Major primary copper producers, many importers, exporters, dealers and merchants, and consumers of copper support the proposed copper duty sus- pension. Some U.S. firms have experienced dif- ficulty in buying domestic copper, particularly during periods of tight supply, and must rely heavily on higher-price imports to meet demand. "The committee has been informed that the temporary suspension of duties on certain forms of copper as provided by H.R. 12281 would not adversely affect the domestic copper mining industry. Indeed, the committee is informed that the duty suspension would be likely to benefit employment in con- struction, transportation and electronics in- dustries, which are major consumers of copper." Basis adjustment for property received in the liquidation of a subsidiary (section 3) This section contains a provision that would allow a private corporation, State Lines, Inc., (New State) which succeeded to the business of a liquidated corporation, States Steamship Company, (Old State) to deduct, as a loss for tax purposes, a payment by New State of a judgment for cargo lost by Old State. The cost to the Federal Government of such a provision would be approximately $1.4 million. Tax law provides that when a corporation acquires another corporation and liquidates the acquired corporation within two years, it must capitalize the liabilities of the acquired corporation. That is, it must treat the liabilities of the acquired corporation as part of the acquiring corporation's 3 basis in the acquired property even though those liabilities might have been deductible for tax purposes by the acquired corporation had it continued in existence. The facts of the instant case are as follows: In 1952 Old State lost a ship at sea. In 1955 the U.S. District Court held that Old State's liability was limited to an amount less than the insurance of the cargo with the result that it owed nothing. On appeal, the U.S. Court of Appeals affirmed the District Court's judgment on May 31, 1957. About a year before that, on July 11, 1956, New State acquired Old State. On June 30, 1957, one month after the Circuit Court affirma- tion, New State liquidated Old State. On November 15, 1957, the same Circuit Court of Appeals, on a petition for rehearing, reversed itself and New State became liable for a liability of Old State. Certiorari was denied by the Supreme Court in early 1959. Because New State had liquidated Old State less than two years after its acquisition, it lost its option under law to treat the liability as a tax loss. This resulted in financial dis- advantage to the corporation in that it had to pay a liability of $1.4 million without claiming it as a tax loss. The New State could have retained the option of treating the Old State liability as a tax loss by waiting until two years after acquisition to liquidate. Presumably, there were financial advantages to liquidation at the time they chose. New State could also have preserved its option by waiting until the period for filing a petition for rehearing or review had passed (thereby making the judgment final) before assuming that no liability existed. Apparently it either chose to take a calculated risk or it acted in error. The specific legal implications of the enrolled bill are that it would exempt this particular liquidation from the rules respecting capitalization of liabilities of recently acquired corporations and permit New State to deduct the payment as a loss when paid in 1959. The Treasury Department, in its views letter on H.R. 12281, states: "In general, the Treasury Department opposes amend- ing tariff legislation to add tax or other provisions which, like section 3, clearly involve special relief 4 for particular taxpayers. From the standpoint of tax policy, section 3 is also objectionable on the grounds of retroactivity " Treasury does not recommend disapproval of the enrolled bill, however, because: -- section 3 is drafted in a manner which would not affect other taxpayers, and thus would not involve a general modification of the Internal Revenue Code; and -- the tariff amendments in sections 1 and 2 are considered to have a significant anti-inflationary effect. Recommendation We believe that H.R. 12281 should be vetoed on the grounds that: -- section 3 involves an undesirable precedent (at a revenue loss of $1.4 million) which could invite others to petition the Congress for relief when they either make errors in corporate tax planning or lose on calculated risks; and ----- extension of the duty suspension on copper could easily be reenacted by the Congress before the end of this session or early next session. A proposed veto message is attached for your consideration. Director Enclosures U.S. DEPARTMENT OF LABOR OFFICE OF THE SECRETARY WASHINGTON OCT 25 1974 Honorable Roy Ash Director, Office of Management : and Budget : Executive Office of the President : Washington, D. C. 20503 Dear Mr. Ash: This is in response to the request of your office for our views on the enrolled enactment of H.R. 12281, "To continue until the close of June 30, 1975, the suspension of duties on certain forms of copper, and for other purposes." This Department would have no objection to the President's approval of this measure insofar as it relates to the duty-free entry of the imports referred to above. The Department defers to the views of the Department of the Treasury on section 3 of the enrolled enactment concerning the Federal tax consequences incidental to the distribution of property in complete liquidation of certain corporations. Sincerely, Secretary of Labor BECEINED THE WHITE HOUSE ACTION MEMORANDUM WASHINGTON LOG NO.: 713 Date: October 25, 1974 Time: 9:30 a.m. rike Duval FOR ACTION: Gooff Signature CC (for information): Warren Haedriks Phil Buchen Jerry Jones Bill Timmons Paul Theis FROM THE STAFF SECRETARY DUE: Date: October 25, 1974, Today Time: 3:00 p.m. SUBJECT: Enrolled Bill H.R. 12281 - Extension of copper duty suspension ACTION REQUESTED: For Necessary Action XX For Your Recommendations Prepare Agenda and Brief Draft Reply For Your Comments Draft Remarks REMARKS: Please return to Kathy Tindle - West Wing PLEASE ATTACH THIS COPY TO MATERIAL SUBMITTED. If you have any questions or if you anticipate a delay in submitting the required material, please K. R. COLE, JR. telephone the Staff Secretary immediately. For the President OF THE TREASURY THE DEPARTMENT THE DEPARTMENT OF THE TREASURY WASHINGTON, D.C. 20220 1789 ASSISTANT SECRETARY OCT 23 1974 Dear Sir: This is in response to your request for the views of the Treasury Department on the enrolled bill H.R. 12281. The first section of the enrolled bill would amend the Appendix to the Tariff Schedules of the United States to extend for one year, that is until June 30, 1975, the sus- pension of duties on copper and copper products provided for in items 911.10, 911.11, 911.13, 911.14, 911.15 and 911.16 of the Tariff Schedules. The second section provides that such amendments shall apply to articles entered, or withdrawn from warehouse, for consumption on or after July 1, 1974. There are strong economic arguments for continuing this tariff suspension, which has generally been in effect since the mid-1960's. Domestic prices are high, copper is a major raw material import, and a lot of trade is involved ($1 billion in 1973). The Treasury Department accordingly would recommend approval of this provision because of its significant though moderate (the tariff rate is one percent), anti-inflationary effect. The third section of the enrolled bill contains an ex- ception to the general tax rule that the basis of property received in a liquidation of a subsidiary within two years after purchase of its stock must be adjusted for the amount of liabilities to which the property was subject or which the parent assumed. The exception would provide that such basis adjustment is not required for property distributed prior to July 1, 1957, if the distributor and distributee did not consider the liability relevant to the value of the stock redeemed, they reasonably relied on a United States district court decision adjudicating the amount of the liability and its affirmance by the United States Court of Appeals, and the amount of such liability was not greater than would be compensated for by insurance. Section 3 would apply without regard to the fact that the Court of Appeals subsequently modified its decision after such distribution occurred. Section 3 also provides that to the extent the liability is not compensated for by insurance or otherwise, it shall be allowed as a deduction for the taxable year when paid and shall be effective in determining income tax liabilities for prior years. - 2 - In general, the Treasury Department opposes amending tariff legislation to add tax or other provisions which, like section 3, clearly involve special relief for particular taxpayers. From the standpoint of tax policy, section 3 is also objectionable on the grounds of retroactivity and because it would reverse a pending case in which the decision on the issue in question is against the taxpayer. We appreciate the fact that the circumstances as pre- sented to Congress -- involving a payment to satisfy a cargo damage claim -- indicate that there are equitable considera- tions which could warrant the relief sought. Furthermore, in view of the way in which section 3 is drafted it would not affect other taxpayers, and it does not involve a general modification of the Internal Revenue Code. On balance, the Treasury Department would prefer to see the tariff amendments approved even though they are coupled with the tax provision described above. Accordingly, the Treasury would not recommend a veto of H.R. 12281. However, the Department does not view the tax amendment as providing a precedent for any other situation or a modification of any general tax principle, and the amendment should not be so construed. Sincerely yours Jederin Frederic W. Certickman Hickman Assistant Secretary Director, Office of Management and Budget Attention: Assistant Director for Legislative Reference, Legislative Reference Division Washington, D.C. 20505 DEPARTMENT OF STATE Washington, D.C. 20520 Honorable Roy L. Ash Director, Office of OCT 22 1974 Management and Budget Washington, D. C. 20503 Dear Mr. Ash: The Secretary has asked me to reply to your communi- cation (Office of Management and Budget Memorandum, dated October 21, signed by Mr. Rommel) requesting our views on H.R. 12281, an enrolled bill extending the suspension of import duties on certain forms of copper. The Department of State has no objection from the standpoint of United States foreign economic rela- tions to the enactment of the proposed legislation. We note, however, that the text of the bill also includes provisions amending the Internal Revenue Code and assume other executive agencies will comment on the effects of the proposed amendment on our tax policy. The Department of State would wish to review any negative positions to determine their impact on U.S. trade. Cordially, Linwood Holton Assistant Secretary for Congressional Relations DEPARTMENT OF COMMERCE GENERAL COUNSEL OF THE DEPARTMENT OF COMMERCE UNITED STATES OF AMERICA Washington, D.C. 20230 OCT 22 1974 Honorable Roy L. Ash Director, Office of Management and Budget Washington, D. C. 20503 Attention: Assistant Director for Legislative Reference Dear Mr. Ash: This is in reply to your request for the views of this Department concerning H.R. 12281, an enrolled enactment "To continue until the close of June 30, 1975, the suspension of duties on certain forms of copper, and for other purposes. 11 The Department of Commerce would have no objection to approval by the President of the provisions in Sections 1 and 2 of H.R. 12281 relating to the temporary suspension of import duties on certain forms of copper. We have no recommendation to make concerning Section 3 which amends the Internal Revenue Code of 1954. Enactment of this legislation would involve no increase in expenditures by this Department. Sincerely, Karl E. Bakke General Counsel OFFICE OF THE SPECIAL REPRESENTATIVE FOR TRADE NEGOTIATIONS EXECUTIVE OFFICE OF THE PRESIDENT WASHINGTON 20506 October 21, 1974 W. L. Rommel, Esquire Assistant Director for Legislative Reference Office of Management and Budget Washington, D. C. 20503 Attention: Mrs. Garziglia Dear Mr. Rommel: Reference is made to your request of October 17, concerning enrolled bills, H.R. 11452, H.R. 11251, H.R. 13631, H.R. 12035, H.R. 7780, H.R. 6191, H.R. 6642, H.R. 11830, and your request of October 21 concerning H.R. 12281. This Office considers that the import duty suspensions provided by these bills provide no reason for withholding Presidential signature. We would, however, yield to the Treasury Department as to the advisability of the Administration's concurrence with the tax riders to each of these duty suspension bills. John Attorney Sincerely, John MEMORANDUM COUNCIL ON INTERNATIONAL ECONOMIC POLICY October 21, 1974 FOR : MR. W. H. ROMMEL, Assistant Director for Legislative Reference, OMB, Room 7201 - New EOB FROM : SKIP HARTQUIST H SUBJECT: Enrolled Bill Request - H.R. 12281 We have no objections to Sections 1 or 2 of H.R. 12281. However, Section 3 relates to changes in the Internal Revenue Code and we defer to the Treasury Department for their views on that section. STATEMENT OF THE INTERIOR United States Department of the Interior OFFICE OF THE SECRETARY March 3, 1849 WASHINGTON, D.C. 20240 OCT 22 1974 Dear Mr. Ash: This responds to your request for our views on the enrolled bill H.R. 12281, "To continue until the close of June 30, 1975, the suspension of duties on certain forms of copper, and for other " purposes. We recommend that the President approve the enrolled bill. H.R. 12281 would amend the Tariff Schedules of the United States by extending from June 30, 1974 to June 30, 1975, the suspension of duties on certain forms of copper such as copper-bearing ores, scrap, blister, and refined copper. Section 3 of the enrolled bill would permit a corporation in a limited type of situation to deduct as a loss its payment of a judgment against it as the successor to the business of a liquidated corporation, when the liquidation occurred before July 1, 1957. The effective rate of duty on unwrought copper products, in accord with the 1967 agreement in Geneva, has been reduced in stages from 1.7 cents per pound of contain copper in 1967 to 0.8 cent per pound effective January 1, 1972. Legislation suspending copper duties was enacted in 1966, and as a result of periodic extensions intro- duced in April 1972 to extend the suspension was not passed and, therefore, duties were reimposed, effective July 1, 1972. Public Law 93-77 reinstated the copper duty suspension, effective July 1, 1973 through June 30, 1974. An examination of salient copper market trends is important for determination of a position on this trade bill. From 1964 to mid- 1970, world copper producers had difficulty in keeping pace with the growing demand. However, after mid-1970, the increased pro- duction capacity of copper producers, coupled with a slowdown in the demand for copper, resulted in a rapid buildup of copper stocks and a decline in world copper prices. Beginning in mid- November 1972, world copper prices rose significantly in response to increased demand for copper and disruptions in the supply of copper from several countries. The ensuing shortage of copper relative to demand has continued to the present. The planned sale of 251,600 tons of surplus copper from the national stockpile during 1974 is equivalent to one-tenth of current annual consump- tion and the consensus is that this quantity will be absorbed into the market without undue disruption. A first offering of 49,873 tons in February was sold at an average bid price of 85.3 cents per pound compared with a domestic producer price of 68 cents. Since there are no discernible factors at this time indicating significant shifts in the copper market detrimental to the copper producer, we favor extension of the copper duty suspension until June 30, 1975. It should be recognized that in the future the domestic producer may be faced with costly labor settlements, pro- spective large investments required to meet pollution control regulations, and periods of reduced demand which could cause an adverse, competitive position compared to the foreign producer. However, it is unlikely that these contingencies would become a serious problem during the period of time covered by the bill under consideration. Sincerely yours, Assistant Secretary of the Interior Honorable Roy L. Ash Director Office of Management and Budget Washington, D.C. 20503 2 THE WHITE HOUSE WASHINGTON October 25, 1974 MEMORANDUM FOR: MR. WARREN HENDRIKS FROM: WILLIAM E. TIMMONS tol SUBJECT: Action Memorandum - - Log No. 713 Enrolled Bill H.R. 12281 - Extension of Copper Duty Suspension The Office of Legislative Affairs concurs in the attached proposal and has no additional recommendations. Attachment ACTION MEMORANDUM WASHINGTON LOG NO.: 713 Date: October 25, 1974 Time: 9:30 a.m. FOR ACTION: Geoff Shepard CC (for information): Warren Hendriks Phil Buchen Jerry Jones Bill Timmons Paul Theis FROM THE STAFF SECRETARY DUE: Date: October 25, 1974, Today Time: 3:00 p.m. SUBJECT: Enrolled Bill H.R. 12281 - Extension of copper duty suspension ACTION REQUESTED: For Necessary Action XX For Your Recommendations Prepare Agenda and Brief Draft Reply For Your Comments Draft Remarks REMARKS: Please return to Kathy Tindle - West Wing PLEASE ATTACH THIS COPY TO MATERIAL SUBMITTED. If you have any questions or if you anticipate C1 Worren X. Hendriks Decretary immediately For the President We assume that the form of this message including the title and the first paragraph, will be revised to conform with the approach taken in the veto message on H.R. 11541--the TO THE HOUSE OF REPRESENTATIVES National Wildlife Refuge System, dated October 22, 1974. I am returning without my approval H.R. 12281, "To continue until the close of June 30, 1975, the suspension of duties on certain forms of copper, and for other purposes." This bill would amend the Tariff Schedules of the United States by extending from June 30, 1974 to June 30, 1975, the suspension of duties on certain forms of copper such as copper- bearing ores, scrap, blister, and refined copper. Unfortunately, the Congress attached to this desirable provision an unacceptable tax rider which would provide tax relief of nearly $1.4 million for a specific corporation by permitting it to treat as a deduction a damage payment that it made in 1959 on behalf of a corporation it had acquired three years earlier and liquidated less than two years after such acquisition. Tax law provides that a corporation acquiring and liquidating another corporation in less than two years must add the acquired corporation's liabilities to the basis of the acquired corpora- tion, thereby losing the option of treating those liabilities as tax losses. In this case, the corporation whose taxes would be relieved by H.R. 12281 liquidated the assets of the acquired corporation within two years of the acquisition before the liability in question had been finally determined. When, as a result of litigation, the acquiring corporation was required to pay the liability of the acquired corporation, it could not treat that payment as a loss. The corporation could have avoided this situation by waiting two years to liquidate or by waiting until the litigation respecting the liability had finally been determined. - 2 - The tax code should not be changed so as to undo the con- sequences of an individual's assumption of risk or error. To do so would invite others who, in retrospect, find that they have made an error in corporate tax planning to similarly petition the Congress for relief, thereby diverting attention from pressing public business. THE WHITE HOUSE October , 1974 CTION MEMORANDUM WASHINGTON LOG NO.: 713 Date: October 25, 1974 Time: 9:30 a.m. FOR ACTION: Geoff Shepard CC (for information): Warren Hendriks Phil Buchen Jerry Jones Bill Timmons Paul Theis FROM THE STAFF SECRETARY DUE: Date: October 25, 1974, Today Time: 3:00 p.m. SUBJECT: Enrolled Bill H.R. 12281 - Extension of copper duty suspension ACTION REQUESTED: For Necessary Action XX For Your Recommendations Prepare Agenda and Brief Draft Reply For Your Comments Draft Remarks REMARKS: Please return to Kathy Tindle - West Wing 1974 OCT 25 AM II 09 MUB- Research PLEASE ATTACH THIS COPY TO MATERIAL SUBMITTED. If you have any questions or if you anticipate a in submitting the required moterial. Warren K. Hendriks telephone inv Start Secretary immediately For the President We assume that the form of this message including the title and the first paragraph, will be revised to conform with the approach taken in the veto message on H.R. 11541--the TO THE HOUSE OF REPRESENTATIVES National Wildlife Refuge System, dated October 22, 1974. Tab witholding a I am returning without my approval h H.R. 12281, " continue OR until the close of June 30, 1975, the suspension of duties on New certain forms of copper, and for other purposes.' " SINSERT "An statement This bill would amend the Tariff Schedules of the United 1 or one States by extending from June 30, 1974 to June 30, 1975, the suspension of duties on certain forms of copper such as copper- bearing ores, scrap, blister, and refined copper. Unfortunately, the Congress attached to this desirable provision an unacceptable tax rider which would provide tax OR relief of nearly $1.4 million for a specific corporation by permitting it to treat as a deduction a damage payment that it or made in 1959 on behalf of a corporation it had acquired three years earlier and liquidated less than two years after such acquisition. are Tax law provides that a corporation acquiring and liquidating another corporation in less than two years must add the acquired corporation's liabilities to the basis of the acquired corpora- tion, thereby losing the option of treating those liabilities as tax losses. In this case, the corporation whose taxes would be relieved by H.R. 12281 liquidated the assets of the acquired corporation within two years of the acquisition before the liability in question had been finally determined. When, as a result of litigation, the acquiring corporation was required to pay the liability of the acquired corporation, it could not treat that payment as a loss. The corporation could have avoided this situation by waiting two years to liquidate or by waiting until the litigation respecting the liability had finally been determined. a. - 2 - The tax code should not be changed so as to undo the con- sequences of an individual's assumption of risk or error. To do so would invite others who, in retrospect, find that they have made an error in corporate tax planning to similarly petition the Congress for relief, thereby diverting attention from pressing public business. THE WHITE HOUSE October , 1974 FOR IMMEDIATE RELEASE OCTOBER 22, 1974 Office of the White House Fress Secretary (Cleveland, Ohio) THE WHITE HOUSE TO THE HOUSE OF REPRESENTATIVES: I am withholding my approval from H.R. 11541, a bill which would amend the National Wildlife Refuge System Administration Act of 1966. I am advised by the Attorney Insert General and I have determined that the absence of my signa-- in 1st ture from this bill prevents it from becoming law. Without in any way qualifying this determination, I am also returning it without my approval to those designated by Congress to Ft receive messages at this time. This bill would amend section 4(d) of the Act of Dick Gilberts according to October 15, 1966 by adding a new standard in determining office the authority of the Secretary of the Interior to allow certain rights-of--way across lands of the National Wildlife COMB, ext 4710) Refuge System. This new standard would require the Secretary to review all reasonable alternatives to the use of such (alsb area, and then make a determination that the proposed right- of-way use is the most feasible and prudent alternative for such purpose. If we are to have adequate energy-transmission and communication facilities, we must have rights-of-way on which to locate them. Of course, when such lands have a special status as wildlife refuges or national parks, we must fully protect this status when portions of these areas are sought for use as rights-of-way ACTION MEMORANDUM WASHINGTON LOG NO.: 713 Date: October 25 1974 Time: 9:30 a.m. Michael Duval FOR ACTION: Croff Shepard CC (for information): Warren Hendriks Phil Buchen Jerry Jones Bill Timmons Paul Theis FROM THE STAFF SECRETARY DUE: Date: October 25, 1974, Today Time: 3:00 p.m. SUBJECT: Enrolled Bill H.R. 12281 - Extension of copper duty suspension ACTION REQUESTED: For Necessary Action XX For Your Recommendations Prepare Agenda and Brief Draft Reply For Your Comments Draft Remarks REMARKS: Please return to Kathy Tindle - West Wing concern in dation records TO PLEASE ATTACH THIS COPY TO MATERIAL SUBMITTED. If you have any questions or if you anticipate a Worren K. Hendriks the STAR Secretary immediately For the President HR12281 Veto ? TO THE HOUSE OF REPRESENTATIVES: I am witholding my approval of H.R. 12281, a bill which would "continue until the close of June 30, 1975, the suspension of duties on certain forms of copper, and for other purposes." I am advised by the Attorney General and -I have determined that the absence of my signature from this bill prevents it from becoming law. Without in any way qualifying this determination, I am also returning it without my approval to those designated by Congress to receive messages at this time. This bill would amend the Tariff Schedules of the United States by extending from June 30, 1974 to June 30, 1975, the suspension of duties on certain forms of copper such as copper-bearing ores, scrap, blister, and refined copper. Unfortunately, the Congress attached to this desirable provision an unacceptable tax rider which would provide tax relief of nearly $1.4 million for a specific corporation by permitting it to treat as a deduction a damage payment that it made in 1959 on behalf of a corporation it had acquired three years earlier and liquidated less than two years after such acquisition. Tax law provides that a corporation acquiring and liquida- ting another corporation in less than two years must add the acquired corporation's liabilities to the basis of the acquired corporation, thereby losing the option of treating those liabilities as tax losses. In this case, the corporation whose taxes would be relieved by H.R. 12281 liquidated the assets of the acquired corporation within two years of the acquisition before the liability in question had been finally determined. When, as a result of litigation, the acquiring corporation was required to pay the liability of the acquired 2 corporation, it could not treat that payment as a loss. The corporation could have avoided this situation by waiting two years to liquidate or by waiting until the litigation respecting the liability had finally been determined. The tax code should not be changed so as to undo the consequences of an individual's assumption of risk or error. To do so would invite others who, in retrospect, find that they have made an error in corporate tax planning to similarly petition the Congress for relief, thereby diverting attention from pressing public business. Geould R. THE WHITE HOUSE, Harren Handrike EXECUTIVE OFFICE OF THE PRESIDENT 10 7:30pm. m. OFFICE OF management AND BUDGET WASHINGTON, D.C. 20503 OCT 24 1974 MEMORANDUM FOR THE PRESIDENT Subject: Enrolled Bill H.R. 12281 - Extension of copper duty suspension Sponsor - Rep. Griffiths (D) Michigan Last Day for Action October 29, 1974 - Tuesday Purpose Continues through June 30, 1975, the suspension of duties on certain forms of copper; and contains a tax rider relating to the basis of property received in liquidations. Agency Recommendations Office of Management and Budget Disapproval (veto message attached) Department of the Treasury Does not recommend disapproval Department of State No objection Department of Labor No objection Department of Commerce No objection (sections 1 and 2) Office of the Special Representative for Trade Negotiations No objection (sections 1 and 2) Council on International Economic Policy No objection (sections 1 and 2) Department of the Interior Approval Discussion The enrolled bill contains the following provisions: Extension of copper duty suspension (sections 1 and 2) Except for a period of one year, the duty on copper ore and articles was suspended from 1966 until June 30, 1974. This Calendar No. 1021 93D CONGRES. SENATE REPORT 2d Session No. 93-1064 SUSPENSION OF DUTIES ON CERTAIN FORMS OF COPPER AUGUST 1, 1974.-Ordered to be printed Mr. LONG, from the Committee on Finance, submitted the following REPORT [To accompany H.R. 12281] The Committee on Finance, to which was referred the bill (H.R. 12281) to continue until the close of June 30, 1975, the suspen- sion of duties on certain forms of copper, having considered the same, reports favorably thereon with amendments and recommends that the bill as amended do pass. I. SUMMARY House bill.-The House bill would continue until July 1975 the suspension of duties on certain forms of copper, with a "peril point" level of $0.51 per pound. The committee bill does not modify the House bill, but includes an amendment unrelated to the subject matter of the House bill. Committee amendment.-The committee amendment permits a corporation in a limited type of situation to deduct as a loss, its pay- ment of a judgment against it as the successor to the business of a liquidated corporation, when the liquidation occurred before July 1, 1957. The amendment is intended to correct an inequity arising from the requirement of present law that the assumption of the liabilities of a corporation liquidated within two years after the purchase of its stock be capitalized, and as a result no deduction would be available when the accrual takes place. At the time of liquidation, in the case presented to the committee, the liability had been determined by the decision of a Federal Court of Appeals and then, after the liquidation had been completed, that same court reversed itself. In this case there- fore the loss, which would have been deductible by the predecessor corporation, was no longer deductible but resulted instead in a basis adjustment. That disallowance has produced an inequitable result, in the opinion of the committee, because the liquidation of the former 38-010 2 3 corporation was carried out in reliance on the earlier decision of the Major primary copper producers, many importers, exporters, deal- Court of Appeals, and the court's reversal of its own helding was not ers and merchants, and consumers of copper support the proposed foreseeable. copper duty suspension. Some U.S. firms have experienced difficulty II. GENERAL STATEMENT in buying domestic copper, particularly during periods of tight supply, and must rely heavily.or higher-price imports to meet demand.) A. DUTY SUSPENSION ON CERTAIN FORMS OF COPPER The committee has been informed that the temporary suspension Legislation suspending the duty of imports of unwrought copper of duties on certain forms of copper as provided by H.R. 12281 would (except nickel copper), copper waste and scrap, copper articles im- not adversely affect the domestic copper mining industry. Indeed, the ported to be used in remanufacture by smelting, and on the copper committee is informed that the duty suspension would be likely to content of certain copper-bearing ores and materials was enacted in benefit employment in construction, transportation and electronics 1966, and, as a result of periodic extensions, was continued through industries, which are major consumers of copper. June 30, 1972. Legislation introduced in April 1972, to continue the It is to be noted that the "peril point," under which the suspension copper duty suspension was not passed and, therefore, duties were of duty would no longer be applicable when the price of copper is reimposed, effective July 1, 1972. Enactment of H.R. 2323 (Public below 51 cents per pound, would be continued. Law 93-77) reinstated the copper duty suspension, effective for a period from July 1, 1973, until June 30, 1974. B. BASIS ADJUSTMENT FOR PROPERTY RECEIVED IN THE LIQUIDATION OF A The rate of duty which is presently suspended under Public Law SUBSIDIARY PRIOR TO JULY 1, 1957 93-77, and which would remain suspended to June 30, 1975, under H.R. 12281, is 0.8 cents per pound on the copper content of the Under existing law, when the stock of a corporation is acquired by articles imported from countries accorded most-favored-nation treat- purchase and the acquired corporation is liquidated within two years, ment. Imports of copper from most Communist countries would con- no gain or loss is recognized on the liquidation (sec. 332) and the basis tinue to be dutiable at existing rates of duty. of the acquired corporation's assets is taken to be the same as the acquir- The previous suspension of duties on copper, beginning in 1966, ing corporation's basis in the purchased stock of the liquidated corpora- was enacted to relieve the domestic supply shortage and for national tion (sec. 334 (b) (2)) In the liquidation, liabilities of the liquidated defense purposes. Market trends indicate that following the period corporation assumed by the acquiring corporation are capitalized and from 1964 until mid-1970, increased copper production capacity, to- added to the acquiring corporation's basis for the assets, even though gether with a decline in demand, resulted in a rapid worldwide buildup the liabilities might have been deductible by the liquidated corpora- of copper stocks and lower world copper prices. However, world tion had it still been in existence. Capitalization of the liabilities is copper prices rose significantly during the fourth quarter of 1972 due required even though the assumed liabilities may have been contin- to increased demand and disruptions in the supply of copper from gent at the time of liquidation. several countries. The resulting shortage of copper relative to demand Application of the rule has resulted in inequitable hardship in the has continued to the present, with consumption plus exports exceeding case of the acquisition of the stock, and subsequent liquidation, of the production plus imports in each successive calendar quarter since mid- States Steamship Company ("Old States"). To understand the in- 1972. As indicated in a recent report by the Bureau of Domestic Com- equity which the committee's provision is intended to correct, a brief merce, domestic copper production is not expected to increase measur- summary of the facts in this case is necessary. ably during 1974. On January 9, 1952, a steamship owned by Old States was lost at Because of this recurrent shortage in domestic copper supply, the sea with a cargo of wheat insured by the U.S. Government. When the Congress enacted and the President signed Public Law 93-214 on United States sued to recover the value of the cargo from Old States, December 28, 1973, authorizing the sale of 251,600 tons of surplus Old States took the position that its liability was limited to an amount copper from the national stockpile. It is anticipated that the sale of less than the insurance on the cargo, with the result that they owed this surplus copper, which is equivalent to one-tenth of current annual nothing. On November 17, 1955, the U.S. District Court (D. Ore.) consumption, will be absorbed without disruption to the market. As held that Old States' liability was SO limited. reported by the Department of the Interior, a first offering on 49,873 In early 1956, a series of transactions took place, which resulted in tons from the copper stockpile in February 1974, was sold at an aver- the acquisition of all of the stock of Old States on July 11 by a newly age bid price of 85.3 cents per pound compared with a domestic pro- formed corporation, State Lines, Inc. ("New States"). While Old ducer price of 68 cents per pound. States was still a wholly owned subsidiary of New States, the opinion Copper imports for 1973 totalled 402,000 tons valued at $493 million, of the District Court was affirmed by the Court of Appeals on May 31, with the principal supplying countries being Canada, Peru, Chile, 1957 (259 F. 2d 458 (9th Cir.). In reliance on that decision, New Mexico, and the Republic of South Africa. Net imports during the States liquidated Old States on June 30, 1957, thereby acquiring all period 1967-1973 accounted for approximately 7 to 8 percent of do- of its assets and assuming all of its liabilities.¹ The liquidation took mestic copper supply. place under the assumption that the Court of Appeals' decision on the liability question would be the final outcome of the case, since that 1 Assumption of liabilities was required by State law. S.R. 1064 S.R. 1064 4 5 decision affirmed the lower court's ultimate findings of fact as to Old It is estimated that enactment of this provision will decrease cor- States' liability. poration income tax liability by about $1.4 million. However, on November 15, 1957, the Court of Appeals, on a petition for rehearing of the liability case, reversed itself and held that Old III. COSTS OF CARRYING OUT THE BILL AND EFFECT ON THE REVENUES States was liable for the full amount of the Government's claim (259 OF THE BILL F. 2d 463). After certiorari was denied by the Supreme Court in early 1959, New States paid the Government $1,455,394 in full settlement of In compliance with section (a) of the Legislative Reorganiza- the liability case. The payment was deducted as a loss on the consoli- tion Act of 1970, the following statement is made relative to the costs dated returns of New States and its affiliated corporations in 1959, and to be incurred in carrying out this bill and the effect on the revenues of the deduction resulted in loss carrybacks to 1957 and 1958. the bill. The committee estimates that the extension of the existing The Internal Revenue Service disallowed the deduction on the suspension of duties on certain forms of copper provided by the bill ground that it was a liability of Old States which, under the provisions will not result in any additional revenue loss or administrative costs. of section 334(b) (2), had to be capitalized and added to the basis of It is estimated by the committee that the amendment permitting the assets acquired by New States and therefore was not deductible. a deduction for a liability assumed in connection with the liquidation In subsequent litigation, the Tax Court (29 T.C.M. 133 (1970)) held of a subsidiary prior to July 1, 1957, will decrease corporation income the settlement deductible by New States on the ground that, in causing tax liability by about $1.4 million. Old States to be liquidated, it had relied on the first decision of the Court of Appeals in the liability case. On appeal, the Court of Appeals IV. VOTE OF COMMITTEE ON REPORTING THE BILL reversed the Tax Court holding and held that the settlement had to be capitalized because of section 334(b) (2) Pacific Transportation Co. & In compliance with section 133 of the Legislative Reorganization Subsidiaries V. Commissioner, 483 F. 2d 209 (9th Cir. 1973). Act, as amended, the following statement is made relative to the vote The Court of Appeals in the latter case made clear its belief that of the committee on reporting the bill. This bill was ordered favorably its holding produced an inequitable result because of New States' reported by the committee without a roll call vote and without reliance upon the court's decision in proceeding with the liquidation.2 objection. Had it been aware of the unforeseen possibility that the Court of Ap- V. CHANGES IN EXISTING LAW peals would reverse itself, New States probably would have waited until final determination before completing the liquidation, thereby In the opinion of the committee, it is necessary, in order to expedite keeping Old States in existence and possibly permitting it to deduct the business of the Senate, to dispense with the requirements of sub- the amount of the liability. In that case, because a consolidated return section 4 of rule XXIX of the Standing Rules of the Senate (relating would have been filed for the entire group, whether or not the liquida- to the showing of changes in existing law made by the bill, as tion occurred, the tax result would have been the same as allowing New reported). States to take the deduction in 1959, when the liability was finally determined. Moreover, the reversal by the Court of Appeals of its own decision was unusual, particularly in this case where the issue involved the review of inferences drawn by the trial judge from his findings of fact. In such cases, a court rarely reconsiders its factual conclusions. The element of unforeseeability especially makes denial of the deduc- tion hard to justify since New States clearly acted in reliance on the earlier decision. The committee's provision permits New States to deduct the amount paid in settlement of the liability, instead of using it as a basis adjust- ment on the liquidation of Old States. The deduction is to be taken into account in determining the loss carrybacks of members of the affiliated group to earlier years. 2 One judge, concurring in the result, observed "It is with great hesitation and con- siderable reluctance that I join in the foregoing opinion. If logical support could be found in the adjudicated authorities, I would introduce into tax law, under circumstances such as these, a principle of equity which would not permit the revenue gathering branch of our government to take advantage of a taxpayer's well intentioned reliance on the action of another branch." 483 F. 2d 209, 215. 3 Even that result may not have been possible because liquidation must take place within two years for section 884(b) (2) to apply and the liability case was not finally resolved until mid-1959, about three years after New States had purchased the stock. S.R. 1064 S.R. 1064 93D CONGRESS HOUSE OF REPRESENTATIVES REPO 2d Session No. 93-1031 EXTENDING UNTIL JULY 1, 1975, OF THE SUSPENSION OF DUTIES ON CERTAIN FORMS OF COPPER MAY 8, 1974.-Committed to the Committee of the Whole House on the State of the Union and ordered to be printed Mrs. GRIFFITHS, from the Committee on Ways and Means, submitted the following REPORT [To accompany H.R. 12281] The Committee on Ways and Means, to whom was referred the bill (H.R. 12281) to continue until the close of June 30, 1975, the suspension of duties on certain forms of copper, having considered the same, report favorably thereon without amendment and recom- mend that the bill do pass. PURPOSE The purpose of H.R. 12281, as reported, is to continue until the close of June 30, 1975, the suspension of duties on certain forms of copper. GENERAL STATEMENT Legislation suspending the duty of imports of unwrought copper (except nickel copper), copper waste and scrap, copper articles im- ported to be used in remanufacture by smelting, and on the copper content of certain copper-bearing ores and materials was enacted in 1966, and, as a result of periodic extensions, was continued through June 30, 1972. Legislation introduced in April, 1972, to continue the copper duty suspension was not passed and, therefore, duties were reimposed, effective July 1, 1972. Enactment of H.R. 2323 (Public Law 93-77) reinstated the copper duty suspension, effective for a period from July 1, 1973, until June 30, 1974. The rate of duty which is presently suspended under Public Law 93-77, and which would remain suspended to June 30, 1975, under H.R. 12281, is 0.8 cents per pound on the copper content of the articles imported from countries accorded most-favored-nation treat- 99-006 2 3 ment. Imports of copper from most Communist countries would con- In compliance with clause 27 (b) of rule XI of the Rules of the House tinue to be dutiable at existing rates of duty. of Representatives, the following statement is made relative to the The previous suspension of duties on copper, beginning in 1966, vote by the committee in reporting the bill. The bill was unanimously was enacted to relieve the domestic supply shortage and for national ordered favorably reported by the committee. defense purposes. Market trends indicate that following the period from 1964 until mid-1970, increased copper production capacity, to- CHANGES IN EXISTING LAW MADE BY THE BILL, As REPORTED gether with a decline in demand, resulted in a rapid worldwide buildup of copper stocks and lower world copper prices. However, world copper In compliance with clause 3 of rule XIII of the Rules of the House prices rose significantly during the fourth quarter of 1972 due to in- of Representatives, changes in existing law made by the bill, as creased demand and disruptions in the supply of copper from several reported, are shown as follows (existing law proposed to be omitted is countries. The resulting shortage of copper relative to demand has enclosed in black brackets, new matter is printed in italic, existing continued to the present, with consumption plus exports exceeding law in which no change is proposed is shown in roman): production plus imports in each successive calendar quarter since mid- 1972. As indicated in a recent report by the Bureau of Domestic Com- TARIFF SCHEDULES OF THE UNITED STATES merce, domestic copper production is not expected to increase measur- ably during 1974. APPENDIX TO THE TARIFF SCHEDULES Because of this recurrent shortage in domestic copper supply, the Congress enacted and the President signed Public Law 93-214 on Rates of duty December 28, 1973, authorizing the sale of 251,600 tons of surplus Item Articles Effective period copper from the national stockpile. It is anticipated that the sale of 1 2 this surplus copper, which is equivalent to one-tenth of current annual consumption, will be absorbed without disruption to the market. As PART 1.-TEMPORARY LEGISLATION reported by the Department of the Interior, a first offering on 49,873 tons from the copper stockpile in February, 1974, was sold at an aver- Subpart B.-Temporary Provisions age bid price of 85.3 cents per pound compared with a domestic pro- Amending the Tariff Schedules ducer price of 68 cents per pound. Copper imports for 1973 totalled 402,000 tons valued at $493 million, with the principal supplying countries being Canada, Peru, Rates of duty Chile, Mexico, and the Republic of South Africa. Net imports during Effective period the period 1967-1973 accounted for approximately 7 to 8 percent of 1-a 1-b 2 domestic copper supply. Major primary copper producers, many importers, exporters, Metal waste and scrap (provided for in part 2, schedule 6), except lead, zinc, dealers and merchants, and consumers of copper support the proposed and tungsten waste and scrap; un- wrought metal (except copper, lead, copper duty suspension. Some U.S. firms have experienced difficulty zinc, and tungsten) in the form of in buying domestic copper, particularly during periods of tight pigs, ingots, or billets (a) which are defective or damaged, or have been supply, and must rely heavily on higher-price imports to meet demand. produced from melted down metal waste and scrap for convenience in Your committee has been informed that the temporary suspension handling and transportation with- of duties on certain forms of copper as provided by H.R. 12281 would out sweetening, alloying, fluxing, or deliberate purifying, and (b) which not adversely affect the domestic copper mining industry. Indeed, the cannot be commercially used with- out remanufacture; relaying or reroll- Committee is informed that the duty suspension would be likely to ing rails; and articles of metal (ex- benefit employment in construction, transportation and electronics cept articles of lead, of zinc, or of tungsten, and not including metal- industries, which are major consumers of copper. bearing materials provided for in schedule 4 or in part 1 of schedule 6 It is to be noted that the "peril point;" under which the suspension and not including unwrought metal of duty would no longer be applicable when the price of copper is provided for in part 2 of schedule 6) to be used in remanufacture by below 51 cents per pound, would be continued. melting: 911.10 Copper waste and scrap. Free No No On or before [6/30/ change. change. 74] 6/30/75. EFFECT ON THE REVENUES OF THE BILL AND VOTE OF THE 911.11 Articles of copper Free No No On or before [6/30/ change. change. 74] 6/30/75. COMMITTEE IN REPORTING THE BILL 911.12 Other Free Free Free On or before 6/30/75: In compliance with clause 7 of rule XIII of the Rules of the House of Representatives, the following statement is made relative to the effect on the revenues of this bill. Your committee estimates that the pro- visions of this bill will result in no additional revenue loss and will result in no administrative costs. H.R. 1031 H.R. 1031 4 Rates of duty Item Articles Effective period 1 2 911. 13 Copper bearing ores and materials Free of duty No change On or before [6/30/74] (provided for in items 602.30 or imposed on 6/30/75 603.50, part 1, schedule 6). copper con- tent under items 602.30 or 603.50. Rates of duty Effective period 1-a 1-b 2 911. 14 Cement copper and copper precipi- Free No No On or before tates (provided for in item 612.02, change. change. [6/30/74] 6/30/75 part 2C, schedule 6). 911. 15 Black copper, blister copper, anode Free No No On or before copper (provided for in item 612.03, change. change. [6/30/74] 6/30/75 part 2C, schedule 6). 911. 16 Other unwrought copper (provided for Free No No On or before in item 612.06, part 2C, schedule 6). change. change. [6/30/74] 6/30/75 H.R. 1031 93D CONGRESS HOUSE OF REPRESENTATIVES REPORT 2d Session No. 93-1406 EXTENDING UNTIL JULY 1, 1975, THE SUSPENSION OF DUTIES ON CERTAIN FORMS OF COPPER OCTOBER 1, 1974.-Ordered to be printed Mr. MILLS, from the committee of conference, submitted the following CONFERENCE REPORT [To accompany H.R. 12281] The committee of conference on the disagreeing votes of the two Houses on the amendments of the Senate to the bill (H.R. 12281) to continue until the close of June 30, 1975, the suspension of duties on certain forms of copper, having met, after full and free conference, have agreed to recommend and do recommend to their respective Houses as follows: The committee of conference report in disagreement the amendment of the Senate to the text of the bill and the amendment of the Senate to the title of the bill. W.D. MILLS, AL ULLMAN, JAMES A. BURKE, H. T. SCHNEEBELI, HAROLD R. COLLIER, Managers on the Part of the House. RUSSELL LONG, HERMAN E. TALMADGE, WALLACE F. BENNETT, Managers on the Part of the Senate. 38-006 JOINT EXPLANATORY STATEMENT OF THE COMMITTEE OF CONFERENCE The managers on the part of the House and the Senate at the conference on the disagreeing votes of the two Houses on the amend- ments of the Senate to the bill (H.R. 12281) to continue until the close of June 30, 1975, the suspension of duties on certain forms of copper, submit the following joint statement to the House and the Senate in explanation of the effect of the action agreed upon by the managers and recommended in the accompanying conference report: The Senate amendment adds a new section 3 to the bill to permit a corporation in a limited type of situation to deduct as a loss its pay- ment of a judgment against it as the successor to the business of a liquidated corporation, when the liquidation occurred before July 1, 1957. The amendment permits a taxpayer to deduct a loss occasioned by a contingent liability created as the result of a reversal of a U.S. Court of Appeals decision which was not foreseeable. The amendment is intended to correct an inequity under existing law SO that taxpayers who have acquired the assets of a liquidated corporation may deduct the unanticipated loss in the year incurred in the same fashion as the liquidated corporation would have been permitted to had it remained in existence. This amendment is reported in technical disagreement. The mana- gers on the part of the House will offer a motion that the House recede from its disagreement to the Senate amendment to the text of the bill, and agree to the same. The managers on the part of the House will offer a motion that the House recede from its disagreement to the amendment of the Senate to the title of the bill, and agree to the same. W.D.MILLs, AL ULLMAN, JAMES A. BURKE, H. T. SCHNEEBELL, HAROLD R. COLLIER, M anagers on the Part of the House. RUSSELL LONG, HERMAN E. TALMADGE, WALLACE F. BENNETT, M anagers on the Part of the Senate. (3) H.R. 1406 H. R. 12281 Ainety-third Congress of the United States of America AT THE SECOND SESSION Begun and held at the City of Washington on Monday, the twenty-first day of January, one thousand nine hundred and seventy-four An Act To continue until the close of June 30, 1975, the suspension of duties on certain forms of copper, and for other purposes. Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, That items 911.10 (relating to copper waste and scrap), 911.11 (relating to articles of copper), 911.13 (relating to copper bearing ores and materials), 911.14 (relating to cement copper and copper precipitates), 911.15 (relating to black copper, blister copper, and anode copper), and 911.16 (relat- ing to other unwrought copper) of the Appendix to the Tariff Sched- ules of the United States (19 U.S.C. 1202) are each amended by striking out "6/30/74" and inserting in lieu thereof "6/30/75". SEC. 2. The amendments made by the first section of this Act shall apply with respect to articles entered, or withdrawn from warehouse, for consumption on or after July 1, 1974. SEC. 3. (a) Notwithstanding the provisions of section 334 of the Internal Revenue Code of 1954 (relating to basis of property received in liquidations), no adjustment to the basis of any property distributed in complete liquidation of a corporation prior to July 1, 1957, shall be made for any liability if- (1) the distributor and distributee did not consider the liability relevant to the value of the stock with respect to which the distri- bution was made, (2) the distributor and distributee reasonably relied upon a decision of a United States district court specifically adjudicating the amount of the liability and its affirmance by the appropriate United States court of appeals, and (3) the amount of the liability SO adjudicated was not greater than would be compensated for by insurance. The provisions of this section apply without regard to whether such decision was subsequently reversed or modified by that United States court of appeals following distribution of such property in complete liquidation. (b) To the extent that the liability described in subsection (a) is not compensated for by insurance or otherwise, the amount thereof shall be allowed as a deduction under the appropriate provision of the Internal Revenue Code of 1954 for the taxable year in which payment thereof was made and shall be effective in determining income tax liabilities of all taxable years prior thereto. Speaker of the House of Representatives. Vice President of the United States and President of the Senate. October 17, 1974 Dear Mr. Director: The following bills were received at the White House on October 17th: S.J. Res. 236 S. 2840 H.R. 7768 H.R. 14225 S.J. Res. 250 S. 3007 H.R. 7780 H.R. 14597 S.J. Res. 251 S. 3234 H.R. 11221 H.R. 15148 S. 355 S. 3473 H.R. 11251 H.R. 15427 S. 605 S. 3698 H.R. 11452 H.R. 15540 S. 628 S. 3792 H.R. 11830 H.R. 15643 S. 1411 S. 3838 H.R. 12035 H.R. 16857 S. 1412 S. 3979 H.R. 12281 H.R. 17027 S. 1769 H.R. 6624 H.R. 13561 S. 2348 H.R. 6642 H.R. 13631 Please let the President have reports and recommendations as to the approval of these bills as soon as possible. Sincerely, Robert D. Linder Chief Executive Clerk The Honorable Roy L. Ash Director Office of Management and Budget Washington, D. C.