Page 3535 TITLE 26-INTERNAL REVENUE CODE 17621 end "(and such corporation shall be treated as an S cor- poration for such taxable year for purposes of para- graph 13))". Subset. (d)(3)(A). Pub. L. 100-697. 2004(e)(19)(3). struck out "or incurred" after "amounts paid". Subset. (d)(4). Pub. L. 100-697. *200410191. inserted at end ..Notwithstanding the preceding provisions of this paragraph. for taxable years beginning after 1987. the applicable percentage for any partnership or S corpora- tion shall be 100 percent if more than 50 percent of such entity's net income for the short taxable year which would have resulted it the entity had not made an elec- tion under section 444 would have been allocated to partners or shareholders who would not have been enti- tled to the benefits of section 806(e012)1C) of the Tax Re- form Act of 1986 with respect to such income." Subset. (d)(5). Pub. L. 100-647. +200109181. added par. (5). Subset. (GO). Pub. L. 100-647. 32004(6)(4KB). added par. (9). Subset. (g). Pub. L. 100-697. §2004(e)(6). substituted including regulations providing for appropriate ad- justments in the application of this section and sec- tions 280H and 444 in cases where— "11)2 or more applicable election years begin in the same calendar year. or "(2) the base year is a taxable year of less than 12 months" for including regulations for annualizing the income and applicable payments of an entity if the base year is a taxable year of leas than 12 months". EFFECTIVE DATE OP 1997 AMTLNDMENT Amendment by Pub. I.,. 105-24 applicable to taxable years beginning after Aug. 5. 1997. see section 1281(e) of Pub. L. 105-24. set out as a note under section 6652 of this title. EFFECTIVE DATE OP 1989 AMENDMENT Amendment by section 7721(c)(12) of Pub. L. 101-239 applicable to returns the due date for which (deter- mined without regard to extensions) is after Dec. 21. 1989. see section 7721(d) of Pub. L. 101-239. set out as a note under section 46