passive asset
(ii)The term “passive asset” includes any stock in another corporation unless— (I)such stock is treated as held by the decedent by reason of an election under paragraph (8), and (II)such stock qualified under subsection (a)(1). (iii)If— (I)a corporation owns 20 percent or more in value of the voting stock of another corporation, or such other corporation has 45 or fewer shareholders, and (II)80 percent or more of the value of the assets of each such corporation is attributable to assets used in carrying on a trade or business,