The exclusion must be allocated to each item of property with built-in gain on a proportional basis.

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Looking at it logically, I assumed that if Congress intended Section 326 of the ATRA to simply exclude from built-in-gains any gain recognized in 2012 or 2013 by an S corporation that had reached the five-year point in its recognition period, it would have written the proposed Section 1374(d)(7)(C) in the same manner as Section 1374(d)(7)(B).

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Through the app, which goes live this week, Sky customers can interact more fully with content than ever before, following and contributing to online chat via an in-built Twitter feed, plus gain easy access to a range of extra information related to the show they are watching.

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"Right now is the perfect time for augmented reality to gain new momentum because hardware finally has the needed sophistication of built-in cameras, " said Orbotix Co-founder and Chief Technology Officer Ian Bernstein.

ENGADGET: Orbotix launches new Sphero AR tools to get the ball rolling on development