of workers taken into account The number of eligible replacement workers taken into account under this section, shall not exceed the average number of H–2A workers employed by the taxpayer during the preceding taxable year. (5) Controlled groups and common control All persons which are treated as a single employer under subsections (a) and (b) of section 52 shall be treated as a single taxpayer for purposes of this section. (6) Application of other rules Rules similar to the following rules shall apply for purposes of this section: (A) Section 51(i) (relating to certain individuals ineligible). (B) Section 51(k) (relating to treatment of successor employers