Deemed transfer rule treats assets received on entity dissolution or reconstitution as taxable transfers charging the transferor's income. A deemed transfer rule treats capital asset or stock-in-trade received by a specified person from a specified entity on dissolution or reconstitution as a transfer by the specified entity in the year of receipt, with any profits or gains included in the specified entity's income and charged under Profits and gains of business or profession or Capital gains; fair market value on the date of receipt is deemed to be the full value of consideration.