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| | revrul87-4 |
 | | Under section 633(d)(3) of the Act, the applicable percentage equals 100 percent reduced by the amount that bears the same ratio to 100 percent as the excess of the applicable value over $5,000,000 bears to $5,000,000. |
 | | Section 633(d)(5) of the Act generally defines 'qualified corporation' as any corporation of which more than 50 percent (by value) of the stock is held by 10 or fewer 'qualified persons,' as defined in section 633(d)(6), and the applicable value of which does not exceed $10,000,000. |
 | | Section 633(d) of the Act achieves this limitation and phase-out for shareholders as a result of the interaction between the application of the transition rule at the corporate level and the provisions of section 333. |
| www.taxlinks.com /rulings/1987/revrul87-4.htm (1122 words) |
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