For purposes of the application of the passive loss limitations,a closely held C corporation is a C corporation where more than 50 percent of the stock is owned by five or fewer individuals at any time during the last half of the taxable year.

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A closely held C corporation is defined as a C corporation where more than 50 percent of the stock is owned by five or fewer individuals at any time during the last half of the taxable year for purposes of the application of the passive loss limitations.

For Purposes of the Application of the Passive Loss Limitations,a