785.5.1. Where a transferor transfers a property, other than a depreciable property, to a transferee in a qualifying exchange, the following rules apply:(a) the transferee is deemed to have acquired the property at the acquisition time and not to have acquired the property at the transfer time;
(b) the transferor’s proceeds of disposition of the property and the transferee’s cost of the property are deemed to be equal to the amount described in the first paragraph of section 785.6; and
(c) where the property is a unit of the transferee and the unit ceases to exist at the time when the transferee acquires it, such time being that when the transferee would but for that cessation have acquired it, paragraphs a and b do not apply in respect of the transferee.