3.26 Ark. Code R. 51-412(c)
In the case of stock or securities acquired by a shareholder in connection with the transactions described in 1. 26-51-412(c), the cost or assessed value of the stock in respect of which the distribution was made, shall be apportioned between such stock and the stock or securities distributed to the shareholder. The basis of each share will be the quotient of the cost or assessed value of the old shares of stock divided by the total number of the old and new shares.
Where the stock distributed in reorganization is materially different from the stock in respect of which the distribution is made, the cost or other basis of the old shares of stock shall be divided between such old stock and the new stock in proportion as nearly as may be to the respective values of each class of stock, old and new, at the time the new shares of stock are distributed, and the basis of each share of stock will be the quotient of the cost or other basis of the class with which such share belongs, divided by the number of shares in the class.
Where the stock in respect of which a distribution in reorganization is made was purchased at different times and prices, and the identity of the lots cannot be determined, any sale of the original stock will be charged to the earliest purchases of such stock (see 2. 26-51-411(a) ), and any sale of the stock distributed in reorganization will be presumed to have been made from the stock distributed in respect of the earliest purchased stock.
Where the stock in respect of which a distribution in reorganization is made was purchased at different times and prices, and the stock distributed in reorganization cannot be identified as having been distributed in respect of any particular lot of such stock then any sale of the stock distributed in reorganization will be presumed to have been made from the stock distributed in respect of the earliest purchased stock.
3.26 Ark. Code R. 51-412(c)