26 U.S.C. § 453A — Special rules for nondealers
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For purposes of this section, the term “deferred tax liability” means, with respect to any taxable year, the product of— (A) the amount of gain with respect to an obligation which has not been recognized as of the close of such taxable year, multiplied by (B) the maximum rate of tax in effect under section 1 or 11, whichever is appropriate, for such taxable year. For purposes of applying the preceding sentence with respect to so much of the gain which, when recognized, will be treated as long-term capital gain, the maximum rate on net capital gain under section 1(h) shall be taken into account.
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