Allocation rule. If an S corpora- tion’s pre-limitation amount for any taxable year exceeds its net recognized built-in gain for that year, the S cor- poration’s net recognized built-in gain consists of a ratable portion of each item of income, gain, loss, and deduc- tion included in the pre-limitation amount.
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Samples: www.govinfo.gov, www.govinfo.gov, www.govinfo.gov