851.22.9. For the purposes of this division,(a) where the amount determined under paragraph c in respect of the disposition of a specified debt obligation by a taxpayer is positive, that amount is the taxpayer’s gain from the disposition of the obligation;
(b) where the amount determined under paragraph c in respect of the disposition of a specified debt obligation by a taxpayer is negative, that amount expressed as a positive number is the taxpayer’s loss from the disposition of the obligation; and
(c) the amount referred to in paragraphs a and b in respect of the disposition of a specified debt obligation by a taxpayer is the positive or negative amount determined by the formula
A − (B + C).
For the purposes of the formula in subparagraph c of the first paragraph,(a) A is the taxpayer’s proceeds of disposition of the specified debt obligation;
(b) B is the tax basis of the obligation to the taxpayer immediately before the time of disposition; and
(c) C is the taxpayer’s transition amount in respect of the disposition of the obligation.