§ 196. Deduction for certain unused business credits
(a)
Allowance of deduction
If any portion of the qualified business credits determined for any taxable year has not, after the application of section
38
(c), been allowed to the taxpayer as a credit under section
38 for any taxable year, an amount equal to the credit not so allowed shall be allowed to the taxpayer as a deduction for the first taxable year following the last taxable year for which such credit could, under section
39, have been allowed as a credit.
(b)
Taxpayer’s dying or ceasing to exist
If a taxpayer dies or ceases to exist before the first taxable year following the last taxable year for which the qualified business credits could, under section
39, have been allowed as a credit, the amount described in subsection (a) (or the proper portion thereof) shall, under regulations prescribed by the Secretary, be allowed to the taxpayer as a deduction for the taxable year in which such death or cessation occurs.
(c)
Qualified business credits
For purposes of this section, the term “qualified business credits” means—
(1)
the investment credit determined under section
46 (but only to the extent attributable to property the basis of which is reduced by section
50
(c)),
(d)
Special rule for investment tax credit and research credit
Subsection (a) shall be applied by substituting “an amount equal to 50 percent of” for “an amount equal to” in the case of—