Adoption of plan of liquidation. For purposes of satisfying the require- ment of adoption of a plan of liquida- tion under section 332, unless a formal plan of liquidation that contemplates the QSub election is adopted on an ear- lier date, the making of the QSub elec- tion is considered to be the adoption of a plan of liquidation immediately be- fore the deemed liquidation described in paragraph (a)(2)(i) of this section.
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