referred to in this paragraph as the Secretary ) determines the application of the amendments made by this section would cause undue burden without a delay, the Secretary may delay the application of such amendments, but such delay shall not apply to any taxable year beginning on or after the date that is 2 years after the enactment of this Act. (ii) Small organization For purposes of clause (i), the term small organization means any organization— (I) the gross receipts of which for the taxable year are less than $200,000