S corporations whose income from passive activities exceeds $25\%$ of the corporation's gross receipts must pay

corporate tax on the excess income from the passive activities. Passive income items for the Excess Net Passive

Income Tax calculation include all of the following except:

A$.$ Gross Rental Income

B$.$ Interest on notes from sales of inventory

C$.$ Portfolio Income including interest and dividends

D$.$ Gain from the sale or exchange of securities