851.22.11R11. The residual portion of a taxpayer’s gain or loss that is from a disposition of a specified debt obligation to which section 851.22.11 of the Act applies is to be allocated to a particular taxation year of the taxpayer to the extent that it has not been allocated to a preceding taxation year, if(a) the particular taxation year ends immediately before the time at which the taxpayer ceases to be a financial institution, otherwise than because it has ceased to carry on a business; and
(b) the disposition occurred before the time referred to in paragraph a.