Income tax liability
(a) Income tax liability defined. For purposes of 1.6425-1, this section, 1.6425-3 and 1.6655-7, relating to excessive adjustment, the term income tax liability means the excess of (1) The sum of (i) The tax imposed by section 11 or 1201(a), or subchapter L of chapter 1 of the Internal Revenue Code, whichever is applicable; plus (ii) The tax imposed by section 55; over (2) The credits against tax provided by part IV of subchapter A of chapter 1 of the Internal Revenue Code.