transfer. (C) Limitations (i) Maximum dollar limitation The amount excluded from gross income by subparagraph (A) shall not exceed the applicable annual limitation under section 224(b) at the time of the qualified SBHA funding distribution. (ii) One-time transfer An individual may make an election under subparagraph (A) only for one qualified SBHA funding distribution during the lifetime of the individual. Such an election, once made, shall be irrevocable. (D) Failure to maintain eligibility (i) In general If, at any time during the testing period, the individual is not an eligible individual, then the aggregate amount of all contributions to the small business health account of the individual made under subparagraph (A)— (I) shall be includible in the gross income of the individual for the taxable year in which occurs the first month in the testing period for which such individual is not an eligible individual, and (II) the tax imposed by this chapter for any taxable year on the individual shall be increased by 10 percent of the amount which is so includible. (ii) Exception for disability or death Subclauses (I) and (II) of clause (i) shall not apply if the individual ceased to be an eligible individual by reason of the death of the individual or the individual becoming disabled (within the meaning of section 72(m)(7)). (iii) Testing period The term testing period means the period beginning with the month in which the qualified SBHA funding distribution is contributed to a small business health account and ending on the last day of the twelfth month following such month. (E) Application of section 72 Notwithstanding section 72, in determining the extent to which an amount is treated as otherwise includible in gross income for purposes of subparagraph (A), the aggregate amount distributed from an individual retirement plan shall be treated as includible in gross income to the extent that such amount does not exceed the aggregate amount which would have been so includible if all amounts from all individual