With respect to capital gains and losses realized or incurred during tax years beginning after December 31, 1990, the following Internal Revenue Code and Regulations shall apply:
* IRC Sections 1211 through 1237, and 1239 through 1257 as in effect on January 1, 1997.
* Corresponding regulations promulgated by the Secretary of the Treasury as in effect on January 1, 1997.
* Any other provisions of the Internal Revenue Code and Regulations necessary for interpreting and implementing the above cited code sections as in effect on January 1, 1997.
However, the provisions of 1. 26-51-815(a) shall not apply to C corporations as defined in IRC Sec. 1361 as in effect on January 1, 1997.
1.26 Ark. Code R. 51-815(a)