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