account. (4) Treated as deduction for individuals and corporations For purposes of chapter 1, the deduction allowed under paragraph (1) shall be treated as a deduction specified in part VI of subchapter B of chapter 1 (relating to itemized deductions for individuals and corporations). (e) Treatment of distributions (1) Tax treatment (A) Exclusion of qualified distributions Any qualified distribution from a small business start-up savings account shall not be includible in gross income. (B) Inclusion of other distributions Any distribution from a small business start-up savings account which is not a qualified distribution shall be included in gross income. (2) Qualified distribution For purposes of this subsection, the term qualified distribution means, with respect to any taxable year, any payment or distribution from a small business start-up savings account— (A) to the extent the amount of such payment or distribution does not exceed the sum of— (i) the aggregate amounts paid or incurred by the taxpayer for such taxable year with respect to the taxpayer’s trade or business for the purchase of equipment or facilities, marketing, training, incorporation, and accounting fees, and (ii) the aggregate capital contributions of the taxpayer with respect to an eligible small business for the taxable year (but only to the extent such amounts are used by such small business for purposes described in clause (i)), and (B) which, in the case of a payment or distribution subsequent to the first payment or distribution from such account (or any predecessor to such account)— (i) is made not later than the close of the 5th taxable year beginning after the date of such first payment or distribution, and (ii) is made with respect to the same eligible small business with respect to which such first payment or distribution was made. (3) Treatment after death of account beneficiary (A) In general If, by reason of the death of the account beneficiary, any person acquires the account beneficiary’s interest in a small business