depreciable property
(i)At the election of the taxpayer, for purposes of this section, the term “depreciable property” includes any real property which is described in section 1221(a)(1). (ii)An election under clause (i) shall be made on the taxpayer’s return for the taxable year in which the discharge occurs or at such other time as may be permitted in regulations prescribed by the Secretary. Such an election, once made, may be revoked only with the consent of the Secretary. (F)In the case of any amount which underis to be applied to reduce basis— (i)depreciable property shall only include depreciable real property for purposes of subparagraphs (A) and (C), (ii)subparagraph (E) shall not apply, and (iii)in the case of property taken into account under section 108(c)(2)(B), the reduction with respect to such property shall be made as of the time immediately before disposition if earlier than the time under subsection (a).