To amend the Internal Revenue Code of 1986 to provide that the provision enacted as part of the Energy Policy Act of 1992 requiring the recognition of precontribution gain in the case of certain partnership distributions to a contributing partner shall be fully prospective, and for other purposes.

Amends the Energy Policy Act of 1992 to make prospective the rules on recognition of precontribution gain in the case of certain distributions to a contributing partner.

Amends the Internal Revenue Code to provide that such gain be subject to tax without netting or precondition losses.

Imposes an interest charge on any deferred tax liability.