851.22.4. Subject to sections 851.22.5 and 851.22.5.1, where a taxpayer that is, in a taxation year, a financial institution holds a specified debt obligation at any time in the year, the following rules apply:(a) there shall be included in computing the taxpayer’s income for the year the amount prescribed in respect of the obligation;
(b) there shall be deducted in computing the taxpayer’s income for the year the amount prescribed in respect of the obligation; and
(c) except as provided by this chapter, paragraphs d and i of section 87 and sections 140 and 141, no amount shall be included or deducted in respect of payments under the obligation, other than fees and similar amounts, in computing the taxpayer’s income for the year.