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$7000 dividend from stern corporation, a U S corporation that had total gross income of 4,000,000 from active conduct of a foreign trade or business

$7000 dividend from stern corporation, a U S corporation that had total gross income of 4,000,000 from active conduct of a foreign trade or business for the immediately preceding three tax years. Stern's total gross income for the same period was $5,000,000.

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