(12) Distributive share of partnership gross income; (13) Income in respect of a decedent; and (14) Income from an interest in an estate or trust. (b) Cross referencesFor items specifically included in gross income, see part II (sec. 71 and following

, the term "qualified trust" means a trust which is created or organized in the United States for the exclusive benefit of designated beneficiaries and with respect to which the requirements of paragraphs (2) and (5) of section 408(a) are met. (2) Cash contributionsA program shall not be treated as a qualified tuition program unless it provides that

, 1986, for exemption from the tax on self-employment income (see section 1401 and 1.1401-1) with respect to services performed by him or her in his or her capacity as a minister, member, or practitioner pursuant to §§1.1402(e)-2A through 1.1402(e)-4A. This section does not apply to applications for exemption under section 1402(e) that are filed before January 1, 1987.

, or an S corporation; (2) Satisfies the gross receipts test of paragraph (d) of this section; and (3) Satisfies the base erosion percentage test of paragraph (e) of this section. (c) Aggregation rules—(1) In general. Solely for purposes of this section and