§ 244. Dividends received on certain preferred stock
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In the case of a corporation, there shall be allowed as a deduction an amount computed as follows: |
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(1) |
First determine the amount received as dividends on the preferred stock of a public utility which is subject to taxation under this chapter and with respect to which the deduction provided in section 247 for dividends paid is allowable. |
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(2) |
Then multiply the amount determined under paragraph (1) by the fraction - |
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(A) |
the numerator of which is 14 percent, and |
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(B) |
the denominator of which is that percentage which equals the highest rate of tax specified in section 11(b). |
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(3) |
Finally ascertain the amount which is 70 percent of the excess of - |
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(A) |
the amount determined under paragraph (1), over |
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(B) |
the amount determined under paragraph (2). |
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If the dividends described in subsection (a)(1) are qualifying dividends (as defined in section 243(b)(1), but determined without regard to section 243(d)(4)) - |
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(1) |
subsection (a) shall be applied separately to such qualifying dividends, and |
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(2) |
for purposes of subsection (a)(3), the percentage applicable to such qualifying dividends shall be 100 percent in lieu of 70 percent. |
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