745.6. For the purposes of section 745.5, where a taxpayer disposes of an interest in a partnership at a particular time, the taxpayer’s share of a partnership loss is to be computed as if(a) the fiscal period of each partnership of which the taxpayer is directly or indirectly a member had ended immediately before the time that is immediately before the particular time;
(b) each share of the capital stock of a corporation that was the property of a partnership referred to in paragraph a at the particular time had been disposed of by the partnership immediately before the end of that fiscal period for proceeds of disposition equal to its fair market value at the particular time; and
(c) each member of a partnership referred to in paragraph a were allocated a share (determined by reference to the member’s agreed proportion for the fiscal period referred to in paragraph a) of any loss (computed without reference to sections 741.2, 743 and 744.6) in respect of a disposition described in paragraph b.