Post-December ordinary loss
For purposes of this paragraph, the term “post-December ordinary loss” means the excess (if any) of—
(i)#
the ordinary losses not described in subparagraph (E)(i) and attributable to the portion of the taxable year after December 31, over
(ii)#
the ordinary income not described in subparagraph (E)(ii) and attributable to such portion of the taxable year.