applicable percentage

(2) Applicable percentage The term “applicable percentage” means the percentage (not in excess of 95 percent) determined by dividing— (A) the applicable amounts paid or incurred during the 3 taxable years immediately preceding the taxable year, by (B) the adjusted taxable income of such corporation for such 3 taxable years.


26 USC § 280H(c)(2)

Scoping language

For purposes of this section
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