to scholarship granting organizations (a) General rule For purposes of section 38, in the case of a corporation, the education scholarship credit determined under this section for the taxable year is the aggregate amount of qualified contributions for the taxable year. (b) Amount of credit The credit allowed under subsection (a) for any taxable year shall not exceed 5 percent of the taxable income (as defined in section 170(b)(2)(D)) of the corporation for such taxable year. (c) Qualified contributions For purposes of this section, the term qualified contribution has the meaning given such term under section 25F. (d) Denial of double benefit No deduction shall be allowed under any provision of this chapter for any expense for which a credit is allowed under this section. (e) Application of volume cap A qualified contribution shall be taken into account under this section only if such contribution is not in excess of the volume cap established under section 3 of the Educational Choice for Children Act . . (2) Conforming amendments Section 38(b) of such Code is amended by striking plus at the end of paragraph (39), by striking the period and inserting , plus at the end of paragraph (40), and by adding at the end the following new paragraph: (41) the education scholarship credit determined under section 45AA(a). . (3) Clerical amendment The table of sections for subpart D of part IV of subchapter A of chapter 1 of such Code is amended by adding at the end the following new item: Sec. 45AA. Contributions to scholarship granting organizations. . (c) Failure of scholarship granting organizations To make distributions (1) In general Chapter 42 of the Internal Revenue Code of 1986 is amended by adding at the end the following new subchapter: I Scholarship Granting Organizations Sec. 4969. Failure to distribute receipts. 4969. Failure to distribute receipts (a) In general In the case of any scholarship granting organization (as defined in section 25F) which has been determined by the Secretary to have failed to satisfy