Full text
there shall be deducted for the purpose of computing the cost amount to the taxpayer of the original share at any time the amount determined by the formula A × (B/C) where A is the cost amount, determined without reference to this section, to the taxpayer of the original share at the time that is immediately before the distribution or, if the original share is disposed of by the taxpayer, before the distribution, at the time that is immediately before its disposition, B is the fair market value of the spin-off share immediately after its distribution to the taxpayer, and C is the total of the fair market value of the original share immediately after the distribution of the spin-off share to the taxpayer, and the fair market value of the spin-off share immediately after its distribution to the taxpayer; and