851.22.22.8. If section 633 deems a partnership (in this section referred to as the “new partnership”) to be a continuation of another partnership (in this section referred to as the “predecessor partnership”) and, at the time that is immediately after the predecessor partnership ceases to exist, the new partnership is a financial institution, in applying sections 851.22.22.3 and 851.22.22.4 in computing the income of the new partnership for the particular fiscal periods of the new partnership that begin on or after the day on which it comes into existence, the new partnership is, on and after that day, deemed to be the same partnership as and a continuation of the predecessor partnership in respect of(a) any amount included under section 851.22.22.1 or deducted under section 851.22.22.2 in computing the predecessor partnership’s income for the predecessor partnership’s transition year;
(b) any amount deducted under section 851.22.22.3 or included under section 851.22.22.4 in computing the predecessor partnership’s income for a fiscal period of the predecessor partnership that begins before the day on which the new partnership comes into existence; and
(c) any amount that would–in the absence of this section and if the predecessor partnership existed and was a financial institution on each day that is the day on which the new partnership comes into existence or a subsequent day and on which the new partnership is a financial institution–be required to be deducted under section 851.22.22.3 or included under section 851.22.22.4, in respect of any of those days, in computing the predecessor partnership’s income.