by the scholarship granting organization. (d) Reasonable cause exception The tax imposed by subsection (a) shall not apply with respect to any failure to make required distributions before the distribution deadline which is not willful and is due to reasonable cause. . (2) Abatement of tax (A) General rule Subsection (b) of section 4962 of such Code is amended by striking or G and inserting G, or H . (B) First tier tax Subsection (a) of section 4963 of such Code is amended by inserting 4968, after 4967, . (C) Taxable event Subsection (c) of section 4963 of such Code is amended by inserting 4968, after 4967, . (3) Correction period Subparagraph (A) of section 4963(e)(2) of such Code is amended by inserting or 4968 after 4942 . (4) Conforming amendment The table of subchapters for chapter 42 of such Code is amended by adding at the end the following new item: Subchapter H—Scholarship granting organizations . (d) Evaluations (1) Definitions In this section— (A) the terms eligible student , qualified elementary and secondary education expenses , and scholarship granting organization have the meanings given such terms in section 25E(c) of the Internal Revenue Code of 1986, as added by this Act