Consistency rules.
(2) Consistency rules. In general, the principles of 1.338-8, concerning asset and stock consistency, apply with respect to section 336(e). However, for this purpose, the application of 1.338-8(b)(1) is modified such that 1.338-8(b)(1)(iii) applies to an asset if the asset is owned, immediately after its acquisition and on the disposition date, by a person or by a related person (as defined in 1.336-1(b)(12)) to a person that acquires, by sale, exchange, distribution, or any combination thereof, five percent or more, by value, of the stock of target in the qualified stock disposition.