year, as a deduction. (b) Amount of deductionFor purposes of subsection (a), the basis for determining the amount of the deduction for any bad debt shall be the adjusted basis provided in section 1011 for determining the loss from the sale or other disposition of property. [(c) Repealed.

(a) General ruleSection 421(a) shall apply with respect to the transfer of a share of stock to an individual pursuant to his exercise of an option granted under an employee stock purchase plan (as defined in subsection (b)) if— (1) no disposition of such share is made by him within 2 years after the

1. Proposal To Change the Fee Payment Schedule for the SENTRI Program 2. Proposal To Mandate Electronic Submission of the SENTRI Program Application and Payment of Fees

controlled foreign corporation as of the close of each quarter of such taxable year, over (B) the amount of earnings and profits described in section 959(c)(1)(A) with respect to such shareholder, or (2) such shareholder's pro rata share of the applicable earnings of such controlled foreign corporation.