applicable excess reserves
(2) Applicable excess reserves (A) In general For purposes of paragraph (1), the term “applicable excess reserves” means the excess (if any) of— (i) the balance of the reserves described in subsection (c)(1) (other than the supplemental reserve) as of the close of the taxpayer’s last taxable year beginning before January 1, 1996 , over (ii) the lesser of— (I) the balance of such reserves as of the close of the taxpayer’s last taxable year beginning before January 1, 1988 , or (II) the balance of the reserves described in subclause (I), reduced in the same manner as under section 585(b)(2)(B)(ii) on the basis of the taxable years described in clause (i) and this clause. (B) Special rule for thrifts which become small banks In the case of a bank (as defined in section 581 ) which was not a large bank (as defined in section 585(c)(2)) for its first taxable year beginning after December 31, 1995 — (i) the balance taken into account under subparagraph (A)(ii) shall not be less than the amount which would be the balance of such reserves as of the close of its last taxable year beginning before such date if the additions to such reserves for all taxable years had been determined under section 585(b)(2)(A), and (ii) the opening balance of the reserve for bad debts as of the beginning of such first taxable year shall be the balance taken into account under subparagraph (A)(ii) (determined after the application of clause (i) of this subparagraph). The preceding sentence shall not apply for purposes of paragraphs (5) and (6) or subsection (e)(1).
26 USC § 593(g)(2)
None identified. Default scope is assumed to be the entire title.