Pub. L. 109–432, div. A, title III, § 306(b), Dec. 20, 2006,
120 Stat. 2951, provided that: “The amendment made by this section [amending this section] shall apply to taxable years beginning after December 31, 2006.”
Section applicable to taxable years beginning after Dec. 31, 2003, see section 1201(k) of
Pub. L. 108–173, set out as an Effective Date of 2003 Amendment note under section
62 of this title.