the return of tax for the taxable year. (b) Qualifying business (1) In general For purposes of this section, the term qualifying business means any person which— (A) meets the gross receipts test of subsection (c) of section 448 for the applicable taxable year under subsection (a)(1)(A), except that subsection (c) of section 448 shall be applied— (i) without regard to paragraph (4) of such subsection, and (ii) by substituting $1,500,000 for $25,000,000 , and (B) with respect to the preceding calendar year, employed an average of not greater than 50 full-time employees (as such term is defined in paragraph (4) of section 4980H(c)) on business days during such calendar year. (2) Special rule For purposes of paragraph (1)(A), in the case of any taxpayer which is not a corporation or a partnership, the gross receipts test of section 448(c) shall be applied in the same manner as if such taxpayer were a corporation or partnership. (3) Full-time equivalents For purposes of paragraph (1)(B), the number of full-time employees shall be determined pursuant to rules similar to the rules described in paragraph (2)(E) of section 4980H(c). (4) Aggregation rules All persons treated as a single employer under subsection (a) or (b) of section 52 or subsection (m) or (o) of section 414 shall be treated as a single person for purposes of paragraph (1)(B). (5) Qualified organizations (A) Inclusion as qualifying business (i) In general For purposes of this section, the term qualifying business shall include any qualified organization. (ii) Definition For purposes of this paragraph, the term qualified organization means an organization which— (I) is described in section 501(c)(3) and exempt from tax under section 501(a), (II) is described in section 170(b)(1)(A), (III) is not described in section 509(a)(3), and (IV) satisfies the requirements under subparagraphs (A) and (B) of paragraph (1). (B) Qualified gross receipts (i) In general For purposes of subsection (a)(1)(A), in the case of a qualified organization, the term qualified