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This is an amount equal to such part of the corporate earnings and profits for the taxable year as are retained for the reasonable needs of the business, minus the net capital gain. The amount of the earnings and profits for the taxable year which are retained is the amount by which the earnings and profits for the taxable year exceed the dividends paid deduction for such year. In general, the credit allowable shall in no case be less than the amount by which $250,000 exceeds the accumulated earnings and profits of the corporation at the close of the preceding taxable year. 26 USCA § 535.

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