excess taxable income
(C)The term “excess taxable income” means, with respect to any partnership, the amount which bears the same ratio to the partnership’s adjusted taxable income as— (i)the excess (if any) of— (I)the amount determined for the partnership under paragraph (1)(B), over (II)the amount (if any) by which the business interest of the partnership, reduced by the floor plan financing interest, exceeds the business interest income of the partnership, bears to (ii)the amount determined for the partnership under paragraph (1)(B). (D)Rules similar to the rules of subparagraphs (A) and (C) shall apply with respect to any S corporation and its shareholders.