¹See Regs. Secs. 1.1245-6(a) and 1.1250-1(c)(1).

²See Sec. 1245(a)(2)(C).

³See Sec. 1245(a)(5) before repeal by the Tax Reform Act of 1986 (TRA 86).

⁴See Sec. 1245(a)(3)(B).

⁵See Sec. 1245(a)(5)(C) before repeal by the TRA 86.

⁶See Sec. 168(e)(2)(A).

⁷The rate is 5% for individuals in the 15% or 10% tax brackets.