Qualification as Sec. 1244 Stock Corporation must not have derived 50 of gross receipts from passive income sources during the immediately preceding 5 tax years, and At the time stock is issued the amount of money and property contributed to both capital and paid in surplus may not exceed $1 millionQualification as Sec. 1244 Stock • Corporation must not have derived > 50% of gross receipts from passive income sources during the immediately preceding 5 tax years, and • At the time stock is issued, the amount of money and property contributed to both capital and paid￾in surplus may not exceed $1 million