net negative adjustment
(1) Accumulated adjustments account (A) In general Except as otherwise provided in this paragraph, the term “accumulated adjustments account” means an account of the S corporation which is adjusted for the S period in a manner similar to the adjustments under section 1367 (except that no adjustment shall be made for income (and related expenses) which is exempt from tax under this title and the phrase “(but not below zero)” shall be disregarded in section 1367(a)(2)) and no adjustment shall be made for Federal taxes attributable to any taxable year in which the corporation was a C corporation. (B) Amount of adjustment in the case of redemptions In the case of any redemption which is treated as an exchange under section 302(a) or 303(a), the adjustment in the accumulated adjustments account shall be an amount which bears the same ratio to the balance in such account as the number of shares redeemed in such redemption bears to the number of shares of stock in the corporation immediately before such redemption. (C) Net loss for year disregarded (i) In general In applying this section to distributions made during any taxable year, the amount in the accumulated adjustments account as of the close of such taxable year shall be determined without regard to any net negative adjustment for such taxable year. (ii) Net negative adjustment For purposes of clause (i), the term “net negative adjustment” means, with respect to any taxable year, the excess (if any) of— (I) the reductions in the account for the taxable year (other than for distributions), over (II) the increases in such account for such taxable year.