with respect to such taxpayer for such taxable year. (2) Special rule for certain sales For purposes of applying paragraph (1), a single-family residence which is sold or transferred in a disqualified sale during the taxable year shall be treated as a single-family residence which is owned by the applicable taxpayer as of the last day of such taxable year. (c) Maximum permissible units The maximum permissible units with respect to any applicable taxpayer for any taxable year shall be determined as follows: In the case of— The maximum permissible units for a hedge fund taxpayer is— The maximum permissible units for any other applicable taxpayer is— the first full taxable year beginning after the applicable date . . . 90 percent of the number of applicable single-family residences owned by the taxpayer on the applicable date 50 plus 90 percent of the number of applicable single-family residences owned by the taxpayer on the applicable date the second taxable year beginning after the applicable date . . . 80 percent of the number of applicable single-family residences owned by the taxpayer on the applicable date 50 plus 80 percent of the number of applicable single-family residences owned by the taxpayer on the applicable date the third taxable year beginning after the applicable date . . . 70 percent of the number of applicable single-family residences owned by the taxpayer on the applicable date 50 plus 70 percent of the number of applicable single-family residences owned by the taxpayer on the applicable date the fourth taxable year beginning after the applicable date . . . 60 percent of the number of applicable single-family residences owned by the taxpayer on the applicable date 50 plus 60 percent of the number of applicable single-family residences owned by the taxpayer on the applicable date the fifth taxable year beginning after the applicable date . . . 50 percent of the number of applicable single-family residences owned by the taxpayer on the applicable date 50 plus 50 percent of the number of applicable