Corporation with subchapter C and subchapter S earnings and profits. If an S corporation that makes the election provided in this paragraph (f)(2) has both subchapter C earnings and profits (as defined in section 1362(d)(3)(B)) and subchapter S earnings and profits in a taxable year of the corporation in which the distribution is made, the dis- tribution is treated as made first from subchapter C earnings and profits, and second from subchapter S earnings and profits. Subchapter S earnings and prof- its are earnings and profits accumu- lated in a taxable year beginning be- fore January 1, 1983 (or in the case of a qualified casualty insurance electing small business corporation or a quali- fied oil corporation, earnings and prof- its accumulated in any taxable year), for which an election under subchapter S of chapter 1 of the Internal Revenue Code was in effect.
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