851.22.15. Where a taxpayer that is a financial institution in a taxation year holds, at the end of the year, a mark-to-market property for the year, the taxpayer is deemed(a) to have disposed of the property immediately before the end of the year for proceeds equal to its fair market value at the time of disposition; and
(b) to have reacquired the property at the end of the year at a cost equal to the proceeds referred to in paragraph a.