net income from foreclosure property

(4) Income from foreclosure property (A) Imposition of tax A tax is hereby imposed for each taxable year on the net income from foreclosure property of every real estate investment trust. Such tax shall be computed by multiplying the net income from foreclosure property by the highest rate of tax specified in section 11(b). (B) Net income from foreclosure property For purposes of this part, the term “net income from foreclosure property” means the excess of— (i) gain (including any foreign currency gain, as defined in section 988(b)(1) ) from the sale or other disposition of foreclosure property described in section 1221(a)(1) and the gross income for the taxable year derived from foreclosure property (as defined in section 856(e)), but only to the extent such gross income is not described in (or, in the case of foreign currency gain, not attributable to gross income described in) section 856(c)(3) other than subparagraph (F) thereof, over (ii) the deductions allowed by this chapter which are directly connected with the production of the income referred to in clause (i).


26 USC § 857(b)(4)

Scoping language

For purposes of this part
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