189.0.1. Notwithstanding section 188, where at any time a partnership is dissolved in circumstances to which Divisions II and III of Chapter IV of Title XI do not apply, a taxpayer who was a member of the partnership immediately before that time may deduct, in computing his income for his first taxation year beginning after that time, an amount determined by the formula
A × (B / C).
For the purposes of the formula in the first paragraph,(a) A is the amount that would, had the partnership not been dissolved, have been deductible under section 188 in computing its income;
(b) B is the fair market value of the taxpayer’s interest in the partnership immediately before that time;
(c) C is the fair market value of all of the interests in the partnership immediately before that time.