Treatment of partial dispositions.
Treatment of partial dispositions. A taxpayer may, for the taxable year in which there is a disposition of substantially all of an activity, treat the part disposed of as a separate activity, but only if the taxpayer can establish with reasonable certainty -
(1) The amount of deductions and credits allocable to that part of the activity for the taxable year under ยง 1.469-1(f)(4) (relating to carryover of disallowed deductions and credits); and
(2) The amount of gross income and of any other deductions and credits allocable to that part of the activity for the taxable year.