Consistency rules.
Consistency rules. In general, the principles of 1.3388, concerning asset and stock consistency, apply with respect to section 336(e). However, for this purpose, the application of 1.3388(b)(1) is modified such that 1.3388(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 1.3361(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.