average indebtedness percentage
(1) In general Except as provided in paragraph (2), the term “average indebtedness percentage” means the percentage obtained by dividing— (A) the average amount (determined under regulations prescribed by the Secretary) of the portfolio indebtedness with respect to the stock during the base period, by (B) the average amount (determined under regulations prescribed by the Secretary) of the adjusted basis of the stock during the base period.