50 percent or more in value
(A)The term “50-percent or greater interest” has the meaning given such term by subsection (d)(4). (B)Paragraph (1) shall not apply to any distribution made in a title 11 or similar case (as defined in). (C) (i)The rules of paragraph (7)(A) of subsection (d) shall apply. (ii)Section 318(a)(2) shall apply in determining whether a person holds stock or securities in any corporation. Except as provided in regulations, section 318(a)(2)(C) shall be applied without regard to the phrase “50 percent or more in value” for purposes of the preceding sentence. (D)For purposes of this subsection, any reference to a controlled corporation or a distributing corporation shall include a reference to any predecessor or successor of such corporation. (E)If there is a distribution to which paragraph (1) applies— (i)the statutory period for the assessment of any deficiency attributable to any part of the gain recognized under this subsection by reason of such distribution shall not expire before the expiration of 3 years from the date the Secretary is notified by the taxpayer (in such manner as the Secretary may by regulations prescribe) that such distribution occurred, and (ii)such deficiency may be assessed before the expiration of such 3-year period notwithstanding the provisions of any other law or rule of law which would otherwise prevent such assessment.