eligible taxpayer
(i)The term “eligible taxpayer” means, with respect to a property, any organization exempt from tax underwhich— (I)acquires from an unrelated person a qualifying brownfield property, and (II)pays or incurs eligible remediation expenditures with respect to such property in an amount which exceeds the greater of $550,000 or 12 percent of the fair market value of the property at the time such property was acquired by the eligible taxpayer, determined as if there was not a presence of a hazardous substance, pollutant, or contaminant on the property which is complicating the expansion, redevelopment, or reuse of the property. (ii)Such term shall not include any organization which is— (I)potentially liable under section 107 of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 with respect to the qualifying brownfield property, (II)affiliated with any other person which is so potentially liable through any direct or indirect familial relationship or any contractual, corporate, or financial relationship (other than a contractual, corporate, or financial relationship which is created by the instruments by which title to any qualifying brownfield property is conveyed or financed or by a contract of sale of goods or services), or (III)the result of a reorganization of a business entity which was so potentially liable. (C)For purposes of this paragraph—