More to the point, Congress could have avoided adding a new subparagraph and simply amended Section 1374(d)(7)(B)(ii) by adding 2012 and 2013.

FORBES: A Closer Look At The Fiscal Cliff Deal's Impact On The Built-In-Gains Recognition Period For S Corporations

By not simply adding 2012 and 2013 to the current subparagraph (B), Congress has created confusion out of what should have been a very straightforward amendment to existing law.

FORBES: A Closer Look At The Fiscal Cliff Deal's Impact On The Built-In-Gains Recognition Period For S Corporations