current year

(3) Definitions For purposes of this section— (A) Holding period The taxpayer’s holding period shall be determined under section 1223; except that— (i) for purposes of applying this section to an excess distribution, such holding period shall be treated as ending on the date of such distribution, and (ii) if section 1296 applied to such stock with respect to the taxpayer for any prior taxable year, such holding period shall be treated as beginning on the first day of the first taxable year beginning after the last taxable year for which section 1296 so applied. (B) Current year The term “current year” means the taxable year in which the excess distribution or disposition occurs.


26 USC § 1291(a)(3)

Scoping language

For purposes of this section
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