recognized built-in loss

(B)The term “recognized built-in loss” means any loss recognized during the recognition period on the disposition of any asset except to the extent the new loss corporation establishes that— (i)such asset was not held by the old loss corporation immediately before the change date, or (ii)such loss exceeds the excess of— (I)the adjusted basis of such asset on the change date, over (II)the fair market value of such asset on such date.

Source

26 USC § 382(h)(2)(B)


Scoping language

For purposes of this section
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