851.22.21.1. The rules in section 851.22.21.2 apply if(a) section 851.22.15 deems the taxpayer to have disposed of a specified debt obligation immediately before the end of the taxpayer’s transition year (in section 851.22.21.2 referred to as the “particular disposition”); and
(b) the specified debt obligation was owned by the taxpayer at the end of the taxpayer’s base year and was not a mark-to-market property of the taxpayer for the taxpayer’s base year.